United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/120
September 1991
Superfund
Record of Decision:
Cryo-Chem, PA
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'SC272-10-;
REPORT DOCUMENTATION i. REPORT HO. 2.
PAGE EPA/ROD/R03-91/120
7Ne and Subtitle
BUPERFUND fiACOUD OF DECISION
Cryo-Chem, PA
Third Remedial Action - Final
7. Autior(s)
». Performing OrgtlnteMion Name md Address
12. Sponsoring Organization None md Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1. Accession No.
5. Report Date
09/30/91
6.
8. Performing Organization Rept No.
10. Proiect/TMk/Work Unit No.
11. Contract(C) or GrantfG) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (UmH: 200 words)
The 19-acre Cryo-Chem site is a metal fabrication facility in Worman, Earl Township,
Berks County, Pennsylvania. Land use in the area is semi-rural, with a woodland area
located northeast of the site, and an onsite stream west of the contaminated area.
Between 1970 and 1982, chemical solvents were used at the facility at a rate of two to
.three 55-gallon drums per year. During this time, a chemical spill occurred at
jbryo-Chem, but cannot be definitely linked to the source of contamination. Well
sampling conducted between 1985 and 1987 showed ground water contamination in
monitoring and residential wells within 1 mile of the site, which led to a removal
action that required the installation of activated carbon filter units in 20 affected
homes. EPA has divided the site into three operable units (OUs) for remediation. A
1989 Record of Decision (ROD) addressed OU1, the contaminated drinking water, by
providing an alternate water supply. A 1990 ROD addressed the remediation of ground
water using air stripping and carbon absorption as OU2. This ROD addresses
contamination in soil caused by past facility operations, which continues to leach
from the soil into the ground water system. The primary contaminants of concern
affecting the soil are VOCs including DCA, and PCE, TCA, and TCE.
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Cryo-Chem, PA
Third Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: VOCs (TCA, TCE, PCE,
ix MBnUHvi •/Qp0n~uMBG TvrnM
xylenes)
e. COSATI Held/Group
A vail abiity Statement
1
19. Security Class (This Report)
None
20. Security Class (Thla Page)
None
21. No. of Pages
82
22. Price
(See ANSH39.18)
See Inatructiom on Roverte
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-91/120
Cryo-Chem, PA
Remedial Action - Final
(Continued)
The selected remedial action for this site includes sampling the area to better define
the extent of the contamination; treating the contaminated soil onsite using vapor
extraction; controlling air emissions using carbon absorption, and disposing of, or
regenerating, any spent carbon; discharging any water captured during in-situ vapor
extraction to the pump and treat system currently under design; and conducting
confirmation soil sampling and air monitoring. The estimated present worth cost for
this remedial action ranges from $53,500 to $66,400 based on the treatment selected.
There are no O&M costs associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS: Although current background contaminant levels are less
than Federal standards, further remediation was deemed necessary to prevent additional
leaching of contaminants from the soil to the ground water. EPA intends to run the soil
vapor extraction system until it is effectively not removing any additional VOCs. EPA
does not intend to continue remediation for OU3 beyond soil vapor extraction since it is
known that the contaminant levels in soil will be below levels that are protective of
human health.
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RECORD OF DECISION
CRYOCHEM SITE
DECLARATION
SITE NAME AND LOCATION
CryoChem Site
Earl Township, Berks County, Pennsylvania
Operable Unit 3
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for Operable Unit 3 at the CryoChem Site (Site), Earl
Township, Berks County, Pennsylvania, chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCLA),
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the Administrative Record for the Site.
The Commonwealth of Pennsylvania concurs with the selected
remedy. A letter of concurrence from the Commonwealth of
Pennsylvania is contained within Appendix D.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare or the environment.
DESCRIPTION OF THE REMEDY
This operable unit is the final action of three operable units
for the Site. The first operable unit addressed the drinking
water by selecting an alternate water supply. The second
operable unit addressed remediation of the ground water. This
operable unit addresses soil contamination at the Site.
The selected remedy includes the following major components:
Sampling the contaminated area (and sampling two other
areas) to better define the extent of the
contamination.
Utilization of soil vapor extraction to remove the
contamination from the soil.
Confirmation sampling.
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STATUTORY DETERMINATIONS
The selected remedy for this operable unit is protective of human
health and the environment, complies with Federal requirements
that are legally applicable or relevant and appropriate to this
action, and is cost-effective. The selected remedy utilizes a
waiver for a State requirement (25 Pa. Code §§ 265.1, 265.300 and
265.310) for capping of the area pursuant to Section 121(d) (4) (D)
of CERCLA, 42 U.S.C. § 9621 (d) (4) (D) , because it will achieve an
equivalent standard of performance. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element. Because this remedy
will not result in hazardous substances remaining onsite above
health-based levels, the five-year review (Section 121 (c) of
CERCLA, 42 U.S.C. § 9621(c)) will not apply to this action.
- ? /
Edwin B. Erickson Date
Regional Administrator
Region III
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Table.of Contents for the Decision Summary
I. Site Name, Location, and Description . i
II. Site History and Enforcement Activity 4
III. Highlights of Community Participation 7
IV. Scope and Role of Operable Unit 3 8
V. Summary of Site Characteristics 9
VI. Summary of Site Risks 19
VII. Description of Alternatives 30
VIII. Summary of the Comparative Analysis of
Alternatives 41
IX. The Selected Remedy 49
X. Statutory Determinations 50
XI. Documentation of Significant Changes 56
List of Tables
Table 1. Summary of Surface Soil Sample Analyses 12
Table 2. Summary of Exposure Pathways 20
Table 3. Exposure Assessment Assumptions 21
Table 4. Cancer Potency Factors (CPFs) and Reference Doses
(RfDs) for Contaminants of Concern 24
Table 5. Cancer Risks Posed by the CryoChem Site Current
Exposures 25
Table 6. Cancer Risks Posed by the CryoChem Site -
Potential Future Exposures 25
Table 7. Cancer Risks Posed by the CryoChem Site - All
Exposure Pathways 26
Table 8. Current Exposure Hazard Indexes (HI) 26
Table 9. Potential Future Exposure Hazard Indexes 27
Table 10. Hazard Indexes for All Exposure Routes 27
Table 11. -Summary of Summers Model Calculations 29
Table 12. Remedial Objectives for OU3 30
Table 13a. Estimated Costs for Alternative 2: Sampling, Soil
Vapor Extraction, Ex-Situ, Removal and Disposal
in an RCRA Subtitle C Landfill, and
Confirmatory Sampling 35
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Table 13b. Estimated Costs for Alternative 2: Sampling, Soil
Vapor Extraction, In-Situ, Removal and Disposal
in an RCRA Subtitle C Landfill, and Confirmatory
Sampling -.--.- 36
Table I4a. Estimated Costs for Alternative 3: Sampling, soil
Vapor Extraction, Ex-8itu, and Confirmatory
Sampling 38
Table 14b. Estimated Costs for Alternative 3: Sampling, Soil
Vapor Extraction, ln-8itu, and Confirmatory
Sampling 38
Table 15. Estimated Costs for Alternative 4: Sampling,
Removal and Disposal in an Off-Site Incinerator,
and Confirmatory Sampling 39
Table 16. Estimated Costs for Alternative 5: Sampling and
Capping 40
Table 17. Chemical-, Action- and Location-Specific ARARs. . . 43
Table 18. Alternative Compliance With ARARs 45
Table 19. Summary of Estimated Costs 47
List of Figures
Figure 1 - Site Location Map 2
Figure 2 - Site Map 3
Figure 3 - Residential Wells Currently Treated by Carbon
Filters 6
Figure 4 - Extent of Ground Water Contamination 10
Figure 5 - Approximate Area of Soil Contamination 13
Figure 6 - Approximate Area of Soil Contamination 14
Figure 7 - Geologic Map 15
Figure 8 - Geologic Cross Section 16
Figure 9 - Locations of Ground Water Monitoring Wells .... 17
Figure 10 - Locations of Preliminary Samples 32
Appendices
Appendix A.
Appendix B.
Appendix C.
Appendix D.
Responsiveness Summary
Administrative Record Index
RI/FS Sampling Data
Letter of Concurrence
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I. Site Name, Location, and Description
The CryoChem Site (Site) is located in the Village of Worman,
Earl Township, Berks County, Pennsylvania, approximately three
miles west of Boyertown, Berks County. The Site is approximately
nineteen acres in size, with CryoChem, Inc.'s manufacturing plant
and office buildings situated on the southern four acres. The
CryoChem, Inc. property is situated along Route 562 in a semi-
rural area of Berks County (Figure 1 - Site Location Map). There
are approximately 100 homes within one mile of the Site.
The Site is located on gently sloping ground found at the base of
Sand Hill. Sand Hill is a topographically high area with 90 feet
of relief located immediately northeast of the Site and covered
primarily with forested woodland. A small stream, which drains
Sand Hill, flows across the western part of the Site and then
through a residential area located south of the CryoChem plant.
The stream eventually discharges to Ironstone Creek that flows
into the Manatawny Creek. Surface runoff from Sand Hill is
combined with drainage from the CryoChem, Inc. fabrication
building and is then channeled to the small stream that runs
along the western part of the Site.
Several farms and single-family homes are located immediately
south and west of the CryoChem, Inc. manufacturing plant (within
one quarter mile). The homes are located in Earl and Douglass
Townships, Berks County, Pennsylvania. Several industries, in
addition to CryoChem, Inc. are located along Route 562 both east
and west of the Site. CryoChem, Inc.'s manufacturing plant
includes a workshop area (fabrication building and Quonset Hut),
a warehouse, and an office building all located on the southern 4
acres of the CryoChem, Inc. property (Figure 2 - Site Map).
According to available information ground water flows from
northwest to southeast beneath the Site and is controlled
predominantly by fractures in the bedrock. Ground water beneath
the CryoChem plant flows southeast towards several homes which
rely upon private wells for drinking water. Past operations at
the Site involved the use of solvents for checking the integrity
of metal welds. The solvent used by CryoChem, Inc. contained
1,1,1-trichloroethane (TCA) which is a hazardous substance as
defined by CERCLA. Volatile organic compounds (VOCs), including
TCA, have-been detected by the U.S. Environmental Protection
Agency (EPA) and the Pennsylvania Department of Environmental
Resources (PADER) at the Site and. in residential wells near the
Site. The Site was added to the National Priorities List (NPL)
in October 1989 based on an observed release of hazardous
substances to the environment.
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oo
v
SOU I .'4000
e lun
n •« « L:—
Source: COM Federal Programs Corporation, 1987
CRYO CHEM
'FOCUSED reASjBIUTY STUDY-OPERABLE UNIT 3
EARL TOWNSHIP. PENNSYLVANIA
FIGURE 1
SITE LOCATION MAP
ENVIRONMENTAL MANAGEMI INC
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MM/I
/
Route Mi?
NOJ JO SCALE
Source: COM Federal Programs Corporation, 1987
CRYO CHEM SITE
FOCUSED FEASIBILITY STUDY-OPERABLE UNIT 3
EARL TOWNSHIP. PENNSYLVANIA
FIGURE 2
SITE MAP
ENVIRONMENTAL MANAGEMENT. INC
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A Remedial Investigation and Feasibility Study (RI/FS) was
completed by tjie potentially responsible parties (PRPs) for the
Site in June 1990. The RI/FS investigated the nature and extent
of contamination at the Site and developed remedial alternatives
that addressed the environmental contamination. A Focused
Feasibility Study (FFS), concentrating on remedial alternatives
specifically for Operable Unit 3, was completed in May 1991.
Operable Unit 3 (OU3: Source Area - soil) addresses soil
contaminated by past facility operations. After EPA issued the
Proposed Plan for OU2 (Area-wide Ground Water) and reviewed
additional information which became available during the public
comment period for OU2, EPA determined that additional
alternatives to remediate contaminated soil at the Site should be
developed and the public provided the opportunity to review and
comment on these remedial alternatives. Thus, EPA decided to
separate response activities at the Site into another operable
unit. The elevated levels of hazardous substances detected in
soil behind the fabrication building indicate that solvent
discarded behind the fabrication building may have contributed to
ground water contamination at the Site. Contaminated soil
continues to contribute to the threat posed by the Site since
hazardous sustances continue to leach from the soil into the
ground water system and into surface water via overland flow.
II. Site History and Enforcement Activity
CryoChem, Inc. has been manufacturing metal products, primarily
pressure vessels, at the Site since 1962. The metal fabrication
process historically included the use of a solvent containing TCA
to wipe away dye used to check for faulty welds. Between 1970
and 1982, CryoChem, Inc. reportedly used the solvent at a rate of
two to three 55-gallon drums per year.
A series of environmental samples collected between 1981 and 1985
by PADER, CryoChem, Inc. and EPA have revealed the presence of
TCA, 1,1-dichloroethane (DCA), 1,1-dichloroethene (DCE),
trichioroethene (TCE), and tetrachloroethene (PCE) in an on-Site
production well and in nearby residential wells. TCA, DCA, DCE,
TCE, and PCE are hazardous substances as defined in CERCLA.
These field investigations and the RI/FS study detected the
presence of TCA, TCE, PCE, DCA, ethylbenzene and xylene in on-
Site soils.
In May 1985, EPA conducted a Site Inspection (SI) at the Site and
collected samples from soil, ground water and surface water. The
results of the sampling would be used later to determine if the
potentially contaminated media at the Site would require cleanup
under Superfund. In June 1985, EPA ranked and scored the Site
according to the Hazard Ranking System (HRS). The HRS evaluates
hazardous substances, defined in CERCLA and identified at a site,
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their migration routes and the potential receptors, (i.e.,
populations thSt could'"be exposed to the contaminants), and then
calculates a score which determines the relative hazard posed by
a site. If a site scores greater than 28.5 it can be recommended
for the National Priorities List (NPL) making it eligible to
receive federal money for investigation and cleanup. The
CryoChem Site scored 28.58, proposed for the NPL in July 1987,
and was added to the NPL in October 1989.
In September 1987, EPA sampled water from residential wells
within 1/4 mile of the Cryochem plant. Due to the detection of
elevated levels of DCE, and other compounds, EPA's Superfund
removal program installed dual, activated-carbon filter units in
thirteen homes. A filter unit was placed in each home where the
removal action level of 23 ug/1 (ppb) of DCE in drinking water
was exceeded. In 1991, EPA placed carbon filter units at five
potentially affected additional homes and one business. Figure 3
- Residential Wells Currently Treated by Carbon Filter - depicts
the residences and business where EPA has installed a carbon
filter unit. A potentially affected residence (or business) is
located in an area that could become contaminated at unacceptable
~ levels.
f-
^ In 1987, EPA met with the PRPs: CryoChem, Inc., C.S. Garber &
£ Sons, Inc. and past owners and operators of CryoChem, Inc. and
the CryoChem, Inc. property. In February 1988, EPA and the PRPs
for the Site entered into a Consent Order for the PRPs to conduct
a RI/FS at the Site. The RI/FS was conducted pursuant to a
<". Statement of Work that was attached to the Consent Order and was
~ completed in June 1990 under the supervision of EPA. The purpose
of the RI/FS was to determine the nature and extent of
contamination at the Site, to assess the risks to human health
and environment posed by the Site, and to develop remedial
alternatives that would address the risks posed by the Site.
To simplify and expedite remedial action at the Site, EPA divided
the Site into three manageable components or operable units. The
three operable units are:
1. Operable Unit 1 (OU1) - Drinking Water Supply;
2. Operable Unit 2 (OU2) - Area wide Ground Water; and,
3. Operable Unit 3 (OU3) - Source Area (soil).
In May 1991, a Focused Feasibility Study (FFS) addressing
Operable Unit 3 was completed, evaluating alternatives for
remediating the soil behind the fabrication building. That
report was the basis for the Proposed Plan and this ROD, but some
revisions have occurred.
»
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Figure 3. RESIDENTIAL WELLS CURRENTLY
TREATED BY CARBON FILTERS
NOT TO SCALE
Iva » HOME WITH CARBON UNIT
NUMBERS REPRESENT
P.O. BOX NUMBERS
K - KOUNTRY KITCHEN RESTAURANT
M = MOBIL GASOLINE STATION
Souctt US. P*.
*«"•"• 474
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III. Highlights of Community Participation
EPA has several public participation requirements which are
described in Sections 113(k)(2)(B), 117(a), and 121(f)(l)(G) of
CERCLA 42 U.S.C. §§ 9613(k) (2) (B), 9617(a) and 9621 (f) (1) (G).
The Proposed Plan for OU3 was released to the public on August 8,
1991. A copy was mailed to each PRP and also to local government
officials. The Proposed Plan defined a 30-day period during
which the public had the opportunity to comment on the Proposed
Plan and the remedial alternatives considered for OU3. The 30-
day public comment period provided in the Proposed Plan started
August 8, 1991 and ended September 9, 1991.
On August 8, 1991, EPA published a notice of availability of the
Proposed Plan and Administrative Record in two local newspapers.
The notice was published in The Reading Times/Eagle and in the
Boyertown Times.
The public was encouraged to review the Proposed Plan and
Administrative Record and to submit comments on EPA's preferred
remedial alternative. The public was given additional
opportunity to comment on the Proposed Plan at a public meeting
held at the Earl Township Building on August 15, 1991. At this
meeting representatives from EPA answered questions and received
comments about the Site, the remedial alternatives under
consideration, and the Preferred Alternative. Community response
to the preferred alternative is summarized within the
"Comparative Analysis of Alternatives" section of this ROD. A
stenographic report of the public meeting was prepared by EPA. A
response to comments received during the 30-day public comment
period is included as part of this ROD in the Responsiveness
Summary (Appendix A).
The RI Report and the FS Reports are included in the
Administrative Record for the Site, located at the Earl Township
Building in August 1991. The Administrative Record contains
documents that served as the basis for EPA's selection of
remedial alternatives for the Site. The availability of these
documents was stated in the Proposed Plan.
The index for the Administrative Record is contained within
Appendix &, This decision document is also based upon comments
contained within a stenographic report of the public meeting on
August 15, 1991 and other comments received by EPA during the 30-
day public comment period, which are included in the Site file
maintained at EPA. The stenographic report and comments will be
added to the Administrative Record.
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IV. Scope and Role of Operable Unit 3
As described above, EPA has divided the CryoChem Site into three
manageable components or operable units. The three operable
units are:
1. Operable Unit 1 (OU1) - Drinking Water Supply;
2. Operable Unit 2 (OU2) - Area Wide Ground Water; and,
3. Operable Unit 3 (OU3) - Source Area (soil).
This ROD addresses OU3, which is the final response action for
the Site. There are no principal threats associated with OU3.
The elevated levels of contaminants detected in soil behind the
fabrication building indicate that solvent spilled onto the
ground behind the fabrication building may have contributed to
ground water contamination at the Site. Contaminated soil
continues to contribute to the threat posed by the Site since
contaminants continue to leach from the soil into the ground
water system. Although the concentrations of contaminants in the
soil were probably much higher than those currently detected, EPA
intends to reduce the remaining contaminants, in order to
minimize the threat to the ground water from the contaminated
soil.
Exposure to the contaminated ground water, which is the drinking
water supply in the area, is the primary risk posed by the Site
since contaminants are ingested via drinking water wells and
inhaled through domestic use of contaminated water. The remedial
action for OUl-Drinking Water is now in the Remedial Design stage
which means that EPA is developing specific plans for
implementation of a clean drinking water supply remedy. The
remedy for OUl-Drinking Water is detailed in the ROD for OUl
prepared by EPA in September 1989.
With EPA oversight, the potentially responsible parties analyzed
area-wide ground water (OU2) under a study completed in June
1990, This study determined that the contaminated ground water
Beneath the Site should be extracted? treated by a process called
air stripping, and discharged to a stream near the Site. In air
stripping -a mixture of air and contaminated water is forced
through a tower concurrently, causing the contaminants to move
from the water to the air, where total organic emissions will be
less than 10 ppm by weight. This remedy is described in detail
in a Record of Decision prepared by EPA in September 1990. EPA
is currently preparing plans to locate and size the treatment
system for the ground water appropriately.
In the Record of Decision for OU2, EPA decided that the ground
water should be remediated to Maximum Contaminant Levels, non-
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zero Maximum Contaminant Level Goals, or background, whichever is
lowest. To th«-extent-practicable, OU3 will remediate the
remaining source of ground water contamination to a degree which
is consistent with the goals of the remedy for OU2.
V. Summary of Site Characteristics
The RI/FS was conducted to determine the extent and nature of
contamination at the Site. The results of the RI are discussed
in this section.
During former operations at the CryoChem, Inc. plant, a solvent
containing TCA was used to clean dye from metal welds. The
amount of solvent reportedly used between 1970 and 1982 was
approximately three 55-galIon drums per year. CryoChem, Inc.
also reported that a spill of an unknown amount of solvent from a
55-galIon drum occurred at some unspecified time in the past.
Spilled solvent would have collected in the shop drains and
flowed, through underground pipes, into a small stream located
along the western edge of the CryoChem, Inc. property.
During the RI, the sump into which the solvent spill reportedly
occurred was examined, hydraulically tested, and determined to be
intact. The pipes through which the solvent would have flowed
into the on-Site stream were also examined, hydraulically tested,
and determined to be intact. Thus, it remains unclear if the
reported spill of solvent caused ground water contamination at
the Site. The approximate extent of ground water contamination
is depicted on Figure 4 - Extent of Ground Water Contamination.
The design specifications and criteria of any ground water
remediation system to be constructed at the Site would be based,
in part, upon the location of contaminated soil and the type and
amount of contaminants identified within the soil. For example,
the extraction wells would be located to ensure that contaminants
leaching from the soil into ground water would be collected by
the extraction wells.
A soil gas survey was performed over areas suspected of
contributing to the volatile organic ground water contamination
in the area. The soil gas survey was used as a screening tool
and correlated with site histories to identify surface soil
sample location. The soil gas survey focused on six areas of
potential soil contamination:
1) CryoChem, Inc. and C.S. Garber Properties
2) Fancyhill Mobil Station
3) R and R Garber, ISC, and Keen Electric Properties
4) CryoChem, Inc. former gravel pit
5) Trexler Property
6) Heimbach Dump site at the Willing's Property
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PENNSYLVANIA
75 MINUTE SERIES (TOPOCRAPH!C>
SCALE 1 24000
looo o iooo jooo KXJO 4000 iooc woo •y» 'if
QU»0*«*U UXAT.O*,
t
Figure 4.
Extent of Groundwater Contaminate
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11
Soil vapor samples were analyzed at 181 locations over five
months throughout the -survey area. The soil probe was driven
three feet into the soil where possible. Occasionally, the probe
could not be driven three feet deep due to shallow bedrock or
ground water. For example, shallow bedrock and ground water
behind the fabrication building precluded the probe from being
driven deeper than twenty inches. Samples were collected at
shallower depths in these particular cases. Soil vapor samples
were measured within the CryoChem, Inc. fabrication building by
drilling holes through the concrete floor of the plant.
The most significant readings observed during the soil gas survey
were around and below the CryoChem, Inc. plant. Other
significant readings were measured at C.S. Garber, ISC, Fancyhill
Mobil Station, R and R Garber, and the Garber estate. These
higher soil gas readings were considered in selecting locations
for obtaining surface soil samples. Moisture affected the survey
instrument throughout the soil gas survey. This effect is
believed to be the cause of soil gas readings at locations where
laboratory analysis of soil samples did not detect significant
volatile organic soil contaminants.
Soil gas survey data were corrected for calibration variability
and instrument drift by subtracting ambient air readings measured
at each sample location from direct readings. After reviewing
corrected data, values of 40 (no units) and above were chosen to
represent possible contaminant sources. This value represents
significant DCA and TCA concentrations (approximately 100 ppm and
70 ppm, respectively) and relatively low concentrations of DCE,
TCE, and PCE (approximately 3-5 ppm) based on the relative
response of each compound. Also the difference in the results of
sample analyses conducted with and without the desiccant was
within a value of 40 for the majority of the samples
(approximately 72%). The analyses that had differences exceeding
a value of 40 had high direct readings (w/o desiccant) which were
included in interpreting results.
Surface soil samples were collected from four of the six areas1
investigated during the soil gas survey, noted below:
1) CryoChem, Inc. and C.S. Garber
2) Fancyhill Mobil Station
3) -A and R Garber, ISC, and Keen Electric
4) Heimbach Dump
Nineteen sample locations were chosen based on site histories,
site characteristics, and the results of the soil gas survey.
The 19 samples were collected from a depth no greater than 36
1 Neither the CryoChem, Inc. former gravel pit nor the
Trexler property were found to be possible contaminant sources,
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inches.
During the RI""and during previous investigation, VOCs were
detected in soil samples collected at the Site. The highest
concentrations were detected in a sample collected from a depth
of 9 to 12 inches behind the fabrication building. The levels of
contaminants found in soil samples are depicted in Table 1 -
Summary of Surface Soil Sample Analyses.
Tabla i. summary of Surface Soil Sample Analyses
Sample Concentration in milligrams per kilogram
Location (mg/kgl
TCA TCE PCE DCA Ethylbenzene Xvlene
1£ .019 .001 .053 ND ND
17 22 .06 .46 4.2 .92 11
ND=Not detected.
The elevated levels of contaminants detected in soil near the
fabrication building indicate that solvent spilled behind the
fabrication building most likely contributed to ground water
contamination at the Site. The elevated concentrations of xylene
and ethylbenzene in soil sample #17 most likely resulted from
minor spills of fuel during refilling of the fuel tank located
near the back door. (See Figures 5 and 6 - Approximate Area of
Soil Contamination.)
The bedrock beneath the Site consists of fractured quartzite
(Hardyston Formation) and crystalline limestone (Leithsville
Formation) overlain by soil derived from weathered bedrock
(overburden) (See Figure 7 - Geologic Map, and Figure 8 -
Geologic Cross Section). A fracture can be considered to be any
break in the rock matrix. Ground water moves predominantly
through the fracture system and through solution cavities formed
when certain minerals in the bedrock dissolve or weather from the
rock matrix over time. Therefore, residential or other wells
penetrating the same fractures or fracture systems containing
ground water contaminated from the Site may themselves become
contaminated. Some residential wells are contaminated by the
same VOCs as those found in ground water beneath the Site and in
soil behind CryoChem, Inc.'s fabrication building.
A large fault, which is a fracture along which two separate
blocks of the bedrock have moved, exists south of the Site. The
fault is significant in that it separates crystalline limestone,
which is also beneath the Site, from red shale. As ground water
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CRYOCHEM FABRICATION BUILDING
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••drock OuHciop
SOURCE COM FEDERAL PROGRAMS CORPORATUN
FNAl NVFS WORK PI AN AUGUST 1M7
Ai i-.i i'f r<>nl.;iiiiliK!lr
-------
ronuTioN
LMIND
*•!«• Mk. .M ft,
o
a,
POOR QUALITY
ORIGINAL
"^"^W U/M
JACA
CORP.
|$
CKYOCXtt. WC.
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rifur* 7.
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ll" «H-)M l^n
-------
Brunswick Formation
in
•s.
600 —
500
400
3OO
200 T
IOO
Le«hsvila Formation
Hardyston Formation
Overturttm
Vertical Seal* I*. tOO'/Vertical Exaggeratioo 4X
Horizontal Seal* I'-400'
AMSL = Above Mean Sea Level
Note: The location* and ortenlalkont
ol al lauH* mual be viewed as
Interpretative, ttnce no Held
measurement* »ere made.
Hw depth ol overburden la InterpretakV*.
-------
17
moves towards the fault it may move upward and discharge at the
surface in theTorm of "springs. Simplified, ground water
discharges as springs since it is easier for ground water to move
up the fault than it is for it to move into the red shale.
During the RI, several ground water monitoring wells were
installed at and near the Site (Figure 9 - Locations of Ground
Water Monitoring Wells). The main objective of installing
monitoring wells was to determine the extent of ground water
contamination. Wells were installed in clusters, (i.e., a
shallow well was installed adjacent to a deep well), for the
purpose of determining if the contamination was confined to
shallow zones or had spread deeper into the ground water system.
Since ground water tends to migrate in discrete zones, such as a
deep fracture, the monitoring wells were constructed to allow a
sample to be collected from either the shallow or deep zone. The
sampling results from these wells suggest that the contamination
is not confined to shallow ground water zones since both shallow
and deep monitoring wells contained contaminants. However, the
concentrations of contaminants in the shallow ground water
samples are typically higher than the concentrations in the
deeper samples suggesting that contaminants may not have sunk to
the bottom of the ground water system. No vinyl chloride, which
is a degradation product of TCE and a known human carcinogen, has
been detected in the residential wells or monitoring wells.
The results of ground water sampling during the RI indicate that
the area of ground water contamination extends from the CryoChem,
Inc. facility nearly 2500 feet southeast to several springs
located along the tributary to Ironstone Creek (near Trout Farm).
Based upon the results of the RI, the plume of contaminated
ground water may extend further south than these springs.
However, the presence of the fault and the large springs near the
Trout Farm suggest that ground water is discharging to surface
water at the springs located along the tributary to Ironstone
Creek. Typically high elevation areas, e.g., Sand Hill or Fancy
Hill, are areas where ground water is recharged by precipitation.
In recharge areas, ground water typically moves from high
elevation to low elevation, or downward. Ground water eventually
moves towards low-lying areas, e.g., swamps and streams, and then
may move upward to discharge into surface water. The presence of
springs can be an indication that ground water is moving upward
to the ground surface.
The lateral dimensions of the plume of contaminated ground water
are not fully defined in the areas southeast of Fancy Hill
Avenue. However, the results of residential well sampling and
the distribution of contaminants in surface water and ground
water near the Trout Farm indicate that the plume continues to
move southeasterly from Fancy Hill Avenue, where it is defined by
residential well sampling, to the springs near the trout Farm.
The volume of contaminated ground water is estimated to be nearly
-------
Figurt 1.
Henitor Mil Location^
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19
1.5 billion gallons assuming a uniform depth of contamination of
300 feet and minimal lateral dispersion of the plume.
Since contaminated ground water discharges to streams on and near
the Site (i.e., into the on-Site stream and into the stream near
the Trout Farm), surface water near the Site is also
contaminated. The level of contamination within the surface
water quickly dissipates downstream from the area where
contaminated ground water introduces the contaminants into the
surface water. Contaminant levels in the surface water are most
likely reduced by volatilization and dilution. The contaminated
surface water is limited to the on-Site stream and to the area
immediately downstream of the springs at the southern extent of
the plume.
The RI results also suggest that a potential source of ground
water contamination exists somewhere north of the Site. Several
residential wells located north of the Site contained the highest
levels of TCE detected (3 samples, 18 ppb to 77 ppb) in the
ground water. Since ground water in the area generally flows
from north to south, ground water contaminated by TCE from an
off-Site source north of CryoChem, Inc. may have migrated onto,
and may continue to migrate onto, the Site. TCE was detected at
high concentrations in homes north of the Site.
A wetland area was identified at the Site. The wetland area is
upstream of the area which has been identified as the source of
the Site-related ground water and surface water contamination and
therefore is most likely not impacted by the Site-related
contamination. One obligate wetland species, the common cattail,
was identified in the wetland area. No other wetland areas,
except the stream itself, were identified.
Appendix C contains a summary of all sampling data collected
during the RI/FS.
VI. Summary of Site Risks
During the Remedial Investigation/Feasibility Study, a baseline
risk assessment was conducted which quantified the risks posed by
the Site if no response action were taken to address Site-related
contamination. Both EPA and JACA Corporation (on behalf of the
PRPs) conducted a baseline risk assessment. The focus of each
risk assessment was to determine health, effects that would result
from exposure to the contaminants of concern associated with the
Site. The results of EPA's assessment were considered
previously, and EPA's results are consistent with results
obtained by JACA Corporation on behalf of the PRPs.
-------
Residential drinking water was sampled twice during the Remedial
Investigation/tEeasibility Study by the Potential Responsible
Parties and many times by EPA. Residential use of ground water
from 14 residential wells near the Site could result in an
upperbound excess lifetime cancer risk of IxlO'2.
This cancer risk level means that if the ground water were not
cleaned, or an alternate water supply were not provided, and
residents continued to use contaminated ground water, not more
than one additional person per one hundred people could contract
cancer due to exposure via ingestion and inhalation. This risk
is in addition to the risk posed by all other sources, e.g., a
30,000 chance out of 1,000,000 of contracting cancer from
smoking. The NCP states that an acceptable risk range is between
IxlO'4 (1 in 10,000 or 100 in 1,000,000) and IxlO'6 (1 in
1,000,000). However, EPA strives to reduce risk to the IxlO'6
level and thus uses this level as the point of departure when it
considers a site remedy.
Other risks posed by the Site result from potential exposures via
incidental ingestion of surface water, dermal contact with
surface water, and fish ingestion. Table 2 - Summary of Exposure
Pathways identifies the exposure pathways associated with the
affected media identified above.
Table 2. Summary of Exposure Pathways
CONTAMINATED MEDIA EXPOSURE PATHWAY
Ground Water Ingestion (Drinking)
Inhalation (Showering)
Surface Water Ingestion (Recreation)
Dermal Contact (Swimming)
Fish Ingestion
Soil Ingestion (Child Trespass)
Dermal Contact
Inhalation (Workers)
These risks are, however, much less than those associated with
residential use of contaminated ground water. The risk to
children and adults from all exposure pathways combined is IxlO'2
(1 additional person per 1 hundred people). The risk estimates
are calculated using various conservative assumptions about the
likelihood of exposure, the amount of exposure, and the toxicity
of the chemicals. The assessment of risk involves many
assumptions about the amount of exposure to contaminants. EPA
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21
strives to select protective remedies and thus utilizes risk
estimating assumptions that are somewhat conservative, e.g., EPA
uses the upper~bourid 'estimates of the mean values of certain
parameters and the 90th percentile for others. For example, EPA
assumes that an individual lives at the same residence for 30
years during which he is exposed to contaminant levels equal to
the upper confidence level of the mean. Table 3 - Exposure
Assessment Assumptions - lists each of the assumptions EPA used
to calculate exposure to contaminants of concern at the Site.
The exposure scenario, which is developed using the assumptions
identified below, is a reasonable maximum exposure scenario.
Table 3. Exposure Assessment Assumptions (for residents unless
otherwise noted)
Adult Mass (kg)
Child Mass (age 3-6, kg)
Length of Lifetime (yrs)
Length of Adult Exposure (yrs)
Length of Child Exposure (yrs)
Tap Water Consumed2 (I/day)
Fish Consumed (g/day)
Surface Water Ingested3 (I/day)
Adult
Child
Recreation Events/year, Adult
Recreation Events/year, Child
Rec. Event duration (hour)
Skin Surface Area, Adult (cm2)
Skin Surface Area, Child (cm2)
Soil Ingestion (mg/event)
Soil Ingestion Events/year
70
17
75
30
4
2
35
0.
0.
30
60
1
18150
7540
200
10
01
1
Chemical intakes are calculated by combining the amount of
chemical (each contaminant of concern) with the duration of the
exposure to the contaminated environmental media.
The chemicals described below were found in the soil behind the
fabrication building, and were considered during the risk
assessment:
1,1,1-Trichloroethane. Inhalation exposure to high
concentrations of 1,1,1-trichloroethane depresses the
central nervous system, alters cardiovascular function, and
2 Tap Water Concentration is 90% upper bound confidence
level of the mean concentration.
3 Surface Water Concentration is the maximum observed
concentration.
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22
damages the lungs, liver, and kidneys in animals and humans.
Irritation-of th«-skin and mucous membranes is also
associated with human exposure to 1,1,1-TCA.
1,1-Dichloroethane. Based on limited evidence of
carcinogenicity in two animal species (rats and mice), EPA
considers 1,1-Dichloroethane to be a class C possible human
carcinogen. Inhalation exposure causes headache, dizziness,
nausea, vomiting, abdominal pain, irritation of mucous
membranes, and liver and kidney damage. Dermal exposure may
cause dermatitis.
Tetrachloroethene. EPA considers tetrachloroethene (PCE) a
Class B2 probable human carcinogen, based on evidence that
PCE causes liver tumors when administered orally to mice.
Non-cancer effects caused by PCE in animals include
neurological depression, increased liver weight/body weight
ratios, decreased body weight, increased liver
triglycerides, decreased DNA content of cells, altered liver
enzyme activity, necrosis, degeneration and polyploidy. The
only toxic effect documented in humans is olfactory
desensitization.
Trichloroethene. EPA considers trichloroethene (TCE) a Class
B2 probable human carcinogen, based on tumors reported in
two strains of mice exposed to TCE by two routes, and in
male rats exposed orally. TCE produces mutations and
unscheduled DNA synthesis in bacteria and mouse cells,
evidence which supports the B2 classification. TCE also
affects bone marrow, central nervous system, liver, and
kidney in animals and humans. Non-cancer effects include
narcosis, enlargement of liver and kidney with accompanying
enzyme changes, depressed heme synthesis, and
immune-suppression.
Ethylbenzene. Ethylbenzene is a skin and eye irritant.
There is some evidence suggesting that it causes adverse
reproductive effects in animals. Oral and inhalation
exposure causes minor liver and kidney changes in rats.
Xylene. Xylene is toxic to fetuses in rats and mice; in
humans, exposure to high levels adversely affects the
centsal nervous system and irritates mucous membranes.
Xylene has not been found to be either a mutagen or
carcinogen.
Current and potential future exposure scenarios were evaluated in
the risk assessment. Since residential wells that are affected
are equipped with carbon filters, ingestion of contaminated
ground water was considered to be a potential future exposure.
For example, an individual could be exposed if a new well was
drilled into the contaminated area or if the existing filter
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23
units were not properly maintained. Thus, the estimates are
based upon levels of contaminants in untreated water. Future use
scenarios also assume that current exposures continue into the
future, i.e., no remediation occurs. Current exposure scenarios
include incidental ingestion of surface water while playing the
contaminated stream, dermal (skin) contact with surface water
while playing in the stream, incidental ingestion of soil by a
child who trespasses behind CryoChem, Inc.'s fabrication
building, and ingestion of fish caught in the contaminated
stream. Dermal contact with contaminated soil by CryoChem Inc.
workers and inhalation of contaminants from soil by CryoChem,
Inc. workers are potential exposure pathways, but were not
evaluated by EPA since the risk is expected to be minimal, i.e.,
less than IxlO"6. JACA evaluated exposure to CryoChem, Inc.
workers and determined that exposures from contaminated soil were
well below (safer than) acceptable risk-based levels. There is
no significant risk from direct contact with the soil.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogen Risk Assessment Verification Endeavor (CRAVE) for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic (cancer-causing) chemicals. CPFs,
which are expressed in units of (mg/kg-day)'1, are multiplied by
the estimated chemical intake of a potential carcinogen, in
mg/kg-day, to provide an upper bound estimate of the excess
lifetime cancer risk associated with the exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CPFs
are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied. CPFs for the
contaminants of concern are shown in Table 4.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals,
which are expected to have no adverse impact. Estimated intakes
of chemicals from environmental media (e.g., the amount of
chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or""animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help to ensure
that the RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur. RfDs for the contaminants of
concern are depicted in Tabl« 4.
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Table 4. Cancer Potency Factors (CPFs) and Reference Doses
(RfDs) for Contaminants of Concern.
Contaminant
Oral Inhaled
RfD RfD
(mg/kg/d)
Oral Inhaled
CPF CPF
(mg/kg/d)'1
TCA
DCA
PCE
TCE
DCE
0.09*
O.lb
0.01a
NA
0.009a
NA
O.lb
NA
NA
NA
NA
0.091a
0.051b
0.011b
0.6a
NA
0.091a
0.0018b
0.017b
1.2a
NA = Not Available
a = IRIS (source of data)
b - HEAST (source of data)
Excess lifetime cancer risks are determined by multiplying the
intake level by the CPF. These risks are probabilities that are
generally expressed in scientific notation (e.g., IxlO""6, or 1 in
1 million). An excess lifetime cancer risk of IxlO"6 indicates
that, as a plausible upper bound, an individual has a one in one
million chance of developing cancer as a result of Site-related
exposure to a carcinogen over his or her entire lifetime. Excess
lifetime cancer risk associated with Site-related exposures are
depicted in Tables 5-7.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the RfO for the
contaminant). By adding the hazard quotients for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated., The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across all media. An HI
greater than l suggests some individuals may be exposed to
noncarcinogens at levels above "safe" levels. The His associated
with Site-related exposures are depicted in Tables 8-10.
Because receptor populations could reasonably be exposed by all
the exposure routes evaluated, risks and hazard indexes from each
exposure route were combined in Tables 7 and 10. Since exposure
to more than one chemical could occur through any of the exposure
pathways, carcinogenic risks and hazard quotients for each
chemical were added to obtain the total risk or HI for each
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25
particular exposure pathway. Cancer risks to children and adults
were also combined under the assumption that children raised near
the Site might continue to live there as adults. Hazard indexes
for children and adults were not combined because they were based
on l year, rather than lifetime, exposures.
Table 5. Cancer Risks Posed by the CryoChem Site Current Exposures
Exposure Risk
Incidental Surface Water Ingestion
Child
Adult
Child+Adult
-7
2.48x10
2.26X10"8
2.71X10"7
Dermal Contact with Surface Water
Child 1.63X10"5
Adult 3.57X10"5
Child+Adult
Fish Ingestion
Child
Adult
Child+Adult
-5
5.20x10
3.11X10'6
5.67X10'6
8.78X10'6
All Current Exposure Routes Combined
Child ° 1.96X10"5
Adult 4.14X10"5
Child+Adult 6.10xlO"5
Table 6. Cancer Risks Posed by the CryoChem Site - Potential
Future Exposures
Exposure
Risk
Drinking Water
Child 1.45X10'3
Adult 2.64xlO"3
Child+Adult 4.09x10
Inhalation. While Showering
Child 2.88x10
Adult 5.25X10"3
Child+Adult 8.13X10"3
All Future Exposure Pathways Combined
Child 4.33X10"3
Adult 7.89xlO'3
-3
-3
Child+Adult
1.22x10
-2
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Table 7. Cancer Risks' "Posed by the CryoChem Site - All Exposure
Pathways
Exposure Risk
Child 4.35XKT3
Adult 7.93xlO~3
Child+Adult 1.23X1CT2
Table 8. Current Exposure Hazard Indexes (HI)
Exposure Hazard Index
Incidental Surface Water Ingestion
Child 2.65xlO~3
Adult 3.43X10'6
Dermal Contact with Surface Water
Child 1.74XKT1
Adult 5.07xlO~2
Fish Ingestion
Child 4.43xlO~2
Adult 1.07xlO~2
All Current Exposure Routes Combined
Child 2.21XKT1
Adult 6.14xlO~2
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27
Table 9. Potential Future Exposure Hazard Indexes
Exposure Hazard Index
Drinking Water
Child 5.76
Adult 1.40
Inhalation while Showering
Child 1.92X10"2
Adult 4.67X10'3
All Future Exposure Pathways Combined
Child 5.78
Adult 1.40
Table 10. Hazard Indexes for All Exposure Routes
Child 6.00
Adult 1.47
The total upper bound excess lifetime cancer risk associated with
the future use scenario including all current use exposures was
1.23xlO~2, or approximately 1 in 100. This means that for every
million people exposed to Site-related contaminants, no more than
10,000 could contract cancer due to their exposure. There are
several important caveats to this estimate:
1. Nearly all the risk was associated with residential well
water, which is currently being treated with carbon filter units.
Therefore, this exposure is not presently occurring.
2. Most of the residential well risk was associated with OCE
which is a Class c carcinogen. This classification means that
animal tumor data for this compound are equivocal. It is
possible that DCE is not carcinogenic in humans.
3. The risk estimate applies only to the most contaminated
homes. Canter risks at the other homes would probably be less.
The total HI associated with the future use scenario was 1.47 for
adults and 6.00 for children. This risk originated almost
entirely from well water. The HI for inhalation may be
artificially low since inhalation RfDs were not available for
four of the compounds.
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28
The following factors contributed elements of uncertainty in the
risk assessments l)-the actual or potential use of the
contaminated stream for recreation, 2) limited sample database
for some media (e.g., surface water), 3) carcinogenic
contaminants at the Site have been found to cause cancer in
animals only, 4) CPFs were extrapolated from high doses given to
animals to low doses received from environmental exposures, 5)
carcinogenic potency was extrapolated from animals to humans on
the basis of dose per surface area, 6) non-cancer effects were
extrapolated from animals to humans by a set of protective 10-
fold uncertainty factors, and 7) data on synergism or antagonism
among the contaminants were not available. However, the majority
of the risk posed by the Site resulted from contaminated ground
water which has an extensive database of high quality samples,
i.e., samples which passed a thorough quality assurance/quality
control review.
The remedy selected for OUl-Drinking Water eliminates the risk
from ingesting ground water and showering. The remedy for OU2-
Ground Water prevents the current contamination from spreading
and would reduce the contamination to safe levels. The remedy
for OU3-Soil removes soil contamination, and acts in conjunction
with the ground water remedy to reduce the principal threat at
the Site. Essentially, the soil will be eliminated as a
significant source of ground water contamination.
There is no significant human health risk due to direct contact
with the soil. The degree of ground water contamination
resulting from leaching of the contaminants from the soil into
the ground water is expected to be within the limits considered
safe. However, the level of soil contamination is expected to
detectably affect the ground water and may increase the remedial
time for OU2.
The Summers method (per EPA/540/2-89/057) estimates
concentrations of volatile organic compounds (VOCs) in soil that
would result in concentrations of the VOCs in ground water above
a specified level (such as a level that is protective of human
health - MCLs, or a level that would detectably affect ground
water - background). This method provides a conservative result,
but here the calculation was especially conservative in light of
the assumption that 90 percent of the precipitation would
infiltrate^.. Commonly, infiltration accounts for less than 25
percent of precipitation. At the Site, however, the contaminated
soil lies beneath a roof overhang that may direct rainfall onto
the soil. Although some runoff undoubtedly occurs, assuming that
90 percent of the rainfall infiltrates results in a maximum
leaching rate for VOCs.
The Summers model was evaluated for PCE, TCA, DCA, TCE, ethyl
benzene and xylene behind the fabrication building. The
allowable level in the soil was examined, first utilizing the
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29
Maximum Contaminant Level (MCL) in the water, which is an
enforceable EPA--set. standard considered to be protective of human
health.
Table 11. Summary of Summers Model Calculations.
VOC Maximum Soil Allowable Soil
Concentration Concentration,
(mg/kg) with MCLs
(mg/kg)
TCA
DCA
PCE
TCE
Ethyl Benzene
Xylene
22
4.2
0.46
0.06
0.92
11
26
88
1.
0.
654
2020
53
53
Some of the allowable concentrations may seem high (e.g., xylene)
due to the fact that the contaminant is not particularly toxic
and adsorbs strongly to organic matter in soil.
Although the levels of contamination in the soil are within the
parameters that EPA would consider protective of human health,
further remediation is necessary to prevent additional leaching
of contaminates from the soil to the ground water. EPA
anticipates that soil remediation will remove the threat of
continued leaching of contaminants to the ground water and
eliminate the need to remove these substances from the ground
water in the future. It should also serve to reduce the amount
of time necessary for the operation of the ground water
remediation system.
No federally listed or proposed endangered or threatened species
are known ^o occur on or near the Site. No endangered or
threatened species listed by the Commonwealth of Pennsylvania are
known to exist on or in the vicinity of the Site, but one State
endangered species, the bog turtle, may exist on or near the
Site. No structures listed on the National Register of Historic
Places exist within Earl Township, Berks County, Pennsylvania.
The Ironstone Bridge, which crosses the Ironstone Creek at
Farmington Avenue in Douglass Township, Berks County,
Pennsylvania, is listed on the National Register of Historic
-------
Places, but is not located near the Site and would not be
impacted by the alternatives considered for remediation of the
Site.
VII. Description of Alternatives
This section of the ROD describes the process of screening and
developing remedial alternatives and discusses in detail each of
the soil remediation alternatives evaluated in the Proposed Plan.
Remedial alternatives were developed to meet the remedial
objectives of this response action. The remedial objectives are
identified in Table 12.
Table 12 - Remedial Objectives for OU3
1. Protect public health, welfare, or environment.
2. Prevent further migration of contaminants from the soil to
the ground water.
3. Prevent soil contaminant migration into unaffected areas.
Based upon the screening and evaluation of potentially applicable
remedial technologies and management or process options and the
requirement within the NCP (see 40 C.F.R. S 300.430(e)(6)) to
evaluate a "No Action" Alternative, the following remedial action
alternatives have been selected for further development and
detailed evaluation:
1. No Action.
2. Sampling of Contaminated Area Followed by Soil Vapor
Extraction (In-Situ or Ex-Situ), Removal of Soil and
Disposal in an Approved RCRA Landfill, and Confirmatory
Sampling.
3. Sampling of Contaminated Area Followed by Soil Vapor
Extracting (In-Situ or Ex-Situ), and Confirmatory
Sampling.
4. Sampling of Contaminated Area Followed by Removal of
Contaminated Soil and Disposal in an Off-Site
Incinerator, and Confirmatory Sampling.
5. Sampling of Contaminated Area Followed by Capping.
The Focused Feasibility Study developed alternatives to remediate
the soil. Based upon information received during the preparation
of the Proposed Plan, the alternatives presented below are not
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31
identical to the alternatives identified in the Feasibility
Study, but employ much of the same technologies and process
options. All""Costs and implementation times presented below are
estimates.
It should also be noted that all alternatives other than "no
action" require further sampling of the contaminated soil area to
be completed prior to remediation of the soil to better define
the area of contamination. Confirmatory sampling would be
conducted at the appropriate time after the remedial action. At
this point, an estimated 70 yd3 of soil needs to be remediated.
The cost of the sampling has been included in each alternative
except for the no action alternative (for which it is not
applicable).
The sampling shall be performed in the area behind the
fabrication building at the following locations (see Figure 10 -
Locations of Preliminary Samples):
1) Soil Vapor Sample Site /13
2) Between Soil Vapor Sample Sites #17 and #22
3) Soil Vapor Sample Site #18
One sample shall also be taken on the east side of the
fabrication building, from the wet area directly in the front of
the door (near railroad tracks). This location is slightly west
of soil vapor probe location 32.
Another sample shall be taken from the drain outside the
fabrication building, also on the east side of the building, if
there is liquid standing in the drain. A minimum of four
preliminary samples will be taken.
Each sample shall be taken at a depth of approximately 8 to 12
inches, and the samples will be analyzed individually for VOCs.
The location of the three confirmatory samples will be determined
in the field.
If significant contamination is found in either of the two
additional samples taken east of the fabrication building, then
the public will be provided with an opportunity to comment on the
proposed remediation of those area(s) since the potential for
contamination of those areas was not addressed in the Proposed
Plan. —
-------
LEGEND
' Locations of
Preliminary Samples
SCALE NOT PflOVDED
Source: Mo
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33
ALTERNATIVE 1:
HO ACTION ^_
Capital Cost : $0
Annual O&M : $0
Present Worth : $0
Implementation : $0
The National Contingency Plan (NCP) requires that EPA
consider a "No Action" Alternative for each site. This
alternative neither provides for soil remediation nor does it
reduce further spread of contamination from the contaminated
soil. This alternative serves as a baseline against which the
other alternatives should be compared.
Under the no action alternative, the Site would remain under
present conditions.
ALTERNATIVE 2:
SAMPLING, SOIL VAPOR EXTRACTION (IN-SITU OR EX-8ITU), REMOVAL AND
DISPOSAL IN A RCRA SUBTITLE C LANDFILL, AND CONFIRMATORY SAMPLING
Capital Cost : $ 106,000 - $ 119,000
Annual O&M : $ 0
Present Worth : $ 106,000 - $ 119,000
Implementation : 9 months
This alternative calls for soil sampling followed by soil vapor
extraction (in-situ or ex-situ), and removal and disposal in a
RCRA Subtitle C Landfill, and sampling to measure the amount of
contaminant reduction.
In ex-situ soil vapor extraction, the soil is excavated, and
treated within the same area of contamination with a vacuum
extraction system. The extracted vapor is captured in a carbon
filter unit and the carbon is properly disposed of or regenerated
according to Federal and State regulations. The air stream is
sampled at predetermined time intervals to provide an ongoing
evaluation of the process. Soil remediation is complete when
equilibrium occurs. The soil is then sampled to measure the
decrease in the contaminant levels to assure that each
contaminant is present at a concentration of less than 2 ppm.
In-situ soil vapor extraction employs the installation of vacuum
extraction probes to remove contaminants from the soil, and
capture of the extracted vapor in a carbon filter system prior to
release of the air to the atmosphere. The contaminants entrained
in the carbon filters will be properly disposed of or regenerated
according to Federal and State regulations. The concentration of
contaminants is measured in the off-gas from the system prior to
carbon treatment. The system operates until it is effectively
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not removing any additional VOCs. The system is then run
intermittently until equilibrium again occurs.
The completion point for the soil remediation completion will be
determined by the performance in the field, based upon achieving
continuous and pulse-pumping equilibrium. The area would be
sampled to confirm that the concentration of each contaminant has
been reduced to less than 2 ppm.
Any water captured during in-situ soil vapor extraction will be
discharged to the ground water pump and treat system, currently
being designed.
Under either method of soil vapor extraction the vapor that is
released to the atmosphere would meet applicable or relevant and
appropriate requirements (ARARs) of Federal and State
environmental laws, e.g. Clean Air Act and 40 C.F.R. § 264.1032.
Since the facility at one time used a solvent that contained
93.5% TCA, the soil is contaminated with a RCRA hazardous waste
(waste codes F001 - F005, 40 C.F.R. § 261.31). Therefore, prior
to removal the soil must be treated to within the concentration
range of 0.5 - 2 ppm. This alternative will meet the
requirements of the Land Disposal Restrictions through a
Treatability Variance under 40 C.F.R. § 268.44.
Under EPA's "contained-in" policy, "contaminated media (i.e.,
debris, soil, groundwater, sediments) that contain RCRA wastes
must be managed as if they were hazardous waste until the media
no longer contain the hazardous waste (i.e., until
decontaminated) or until they are delisted. To date, the agency
has not issued any definitive guidance as to when, or at what
levels, environmental media contaminated with hazardous waste no
longer contain the hazardous waste. Until such guidance is
issued, [EPA] or authorized States may determine these levels on
a case-specific basis. [EPA] also suggests that when making a
determination as to when contaminated media no longer contains a
hazardous waste that a risk assessment approach be used that
addresses the public health and environmental impacts of the
hazardous constituents remaining." 56 Fed. Reg. 24456 (May 30,
1991). After the completion of the soil vapor extraction or
venting, the contaminated soil will no longer contain a RCRA
hazardous waste. Based upon the results of the confirmation
sampling *ad landfill availability, EPA may seek to discard the
soil as non-hazardous.
Though after treatment the soils will no longer contain hazardous
substances, for costing purposes, it will be assumed that all
excavated soils will be treated as hazardous waste.
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35
The treated soil will be loaded into 55-gallon drums, and
transported to~S RCRA "Subtitle C landfill for disposal. The
excavated area would be backfilled with compacted common earth,
covered with topsoil, and seeded with grass. Since the
contamination is removed, there are no operation and maintenance
costs.
The estimated capital cost for Alternative 2 is depicted in
Tables I3a and I3b.
Table 13a. Estimated Costs for Alternative 2: Sampling, Soil
Vapor Extraction, Ex-Situ, Removal and Disposal in an RCRA
Subtitle C Landfill, and Confirmatory Sampling
Preliminary Sampling/Analysis and
Soil Vapor Venting/Confirmatory Sampling 32,000
Transport to Landfill 1,200
Loading 1,200
Disposal at Hazardous Waste Landfill 29,050
Backf i11 and Revegetation 1,000
Health and Safety Equipment 1.000
Subtotal 65,450
Bid Contingency (15%) 9,818
Scope Contingency (20%) 13.090
Construction Subtotal 88,358
Permitting and Legal Activities (5%) 4,418
Engineering Design (7%) 6,185
Construction Services (8%) 7.069
Total Capital Cost 106,029
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31
Table 13b. Estimated Costs for Alternative 2: Sampling, Soil
Vapor Extraction/ in-Situ, Removal and Disposal in an RCRA
Subtitle C Landfill, and Confirmatory Sampling
Preliminary Sampling/Analysis and
Soil Vapor Extraction/Confirmatory Sampling 40,000
Transport to Landfill 1,200
Loading 1,200
Disposal at Hazardous Waste Landfill 29,050
Backfill and Revegetation 1,000
Health and Safety Equipment 1.000
Subtotal 73,450
Bid Contingency (15%) 11,018
Scope Contingency (20%) 14.690
Construction Subtotal 99,158
Permitting and Legal Activities (5%) 4,958
Engineering Design (7%) 6,941
Construction Services (8%) 7.933
Total Capital Cost 118,989
ALTERNATIVE 3: '
SAMPLING, SOIL VAPOR EXTRACTION (IN-SITU OR EX-SITU), AND
CONFIRMATORY SAMPLING
Capital Cost : $ 53,500 - $ 66,400
Annual O&M : $ 0
Present Worth : $ 53,500 - $ 66,400
Implementation : 9 months
This alternative employs soil sampling followed by soil vapor
venting or extraction. The area would be sampled to measure the
amount of contaminant reduction.
As described above, in ex-situ soil vapor extraction, the soil is
excavated, and treated within the same area of contamination with
a vacuum extraction system. The extracted vapor is captured in a
carbon filter unit, and the carbon is properly disposed of or
regenerated according to Federal and State regulations. The air
stream is sampled at predetermined time intervals to provide an
ongoing evaluation of the process. Soil remediation is complete
when equilibrium occurs. The soil is then sampled to measure the
decrease in the contaminant levels to assure that each
contaminant is present at a concentration of less than 2 ppm.
In-situ soil vapor extraction employs the installation of vacuum
extraction probes to remove contaminants from the soil, and
capture of the extracted vapor in a carbon filter system prior to
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37
release of the air to the atmosphere. The contaminants entrained
in the carbon iilters_will be properly disposed of or regenerated
according to Federal and State regulations. The concentration of
contaminants is measured in the off-gas from the system prior to
carbon treatment. The system operates until it is effectively
not removing any additional VOCs. The system is then run
intermittently until equilibrium again occurs. The completion
point for the soil remediation will be determined by the
performance in the field, based upon achieving continuous and
pulse-pumping equilibrium. The area would be sampled to confirm
that the concentration of each contaminant has been reduced to
less than 2 ppm.
Any water captured during in-situ soil vapor extraction will be
discharged to the ground water pump and treat system, currently
being designed.
Under either method of soil vapor extraction the vapor that is
released to the atmosphere would meet applicable ARARs, e.g.
Clean Air Act and 40 C.F.R. § 264.1032.
Since the facility at one time used a solvent that contained
93.5% TCA, the soil is contaminated with a RCRA hazardous waste
(waste codes F001 - F005, 40 C.F.R. S 261.31). The Land Disposal
Restrictions are not ARARs for this alternative, however, since
the waste would be treated in the same area of contamination.
After the completion of the soil vapor extraction the
contaminated soil will no longer contain a hazardous substance,
even based upon the current risk assessment.
The estimated capital cost for Alternative 3 is depicted in
Tables I4a and 14b.
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38
Table 14a. Estimated Costs for Alternative 3: Sampling, Soil
Vapor Extraction, Ex-Situ, and Confirmatory Sampling
Preliminary Sampling/Analysis and
Soil Vapor Venting/Confirmatory Sampling 32,000
Health and Safety Equipment i.ooo
Subtotal 33,000
Bid Contingency (15%) 4,950
Scope Contingency (20%) 6.600
Construction Subtotal 44,550
Permitting and Legal Activities (-5%) 2,228
Engineering Design (7%) 3,119
Construction Services (8%) 3.564
Total Capital Cost 53,460
Table 14b. Estimated Costs for Alternative 3: Sampling, Soil
Vapor Extraction, In-8itu, and Confirmatory Sampling
Preliminary Sampling/Analysis and
Soil Vapor Extraction/Confirmatory Sampling 40,000
Health and Safety Equipment 1.000
Subtotal 41,000
Bid Contingency (15%) 6,150
Scope Contingency (20%) 8.200
Construction Subtotal 55,350
Permitting and Legal Activities (5%) 2,768
Engineering Design (7%) 3,875
Construction Services (8%) 4.428
Total Capital Cost 66,420
ALTERNATIVE 4:
SAHFLXNS, REMOVAL AMD DXS?CSAL VIA AM OFF-SITE INCINERATOR,
CONFIRMATORY SAMPLING
Capital cost : $ 190,000
Annual O&M : $ 0
Present Worth : $ 190,000
Implementation : 2 months
In this alternative the contaminated soil would be
transported to a RCRA-permitted Subtitle C incinerator for
treatment and disposal. After excavation, the area would be
sampled to measure the amount of contaminant reduction. Since
the contamination is removed, there would be no operation and
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39
maintenance costs.
This alternative will meet the requirements of the Land
Disposal Restrictions through a Treatability Variance under 40
C.F.R. S 268.44. This Variance will result in the use of
incineration to attain the Agency's treatment ranges for the
contaminated soil at the Site.
The estimated capital cost for Alternative 4 is depicted in
Tabl* 15.
Table 15. Estimated Costs for Alternative 4: Sampling, Removal
and Disposal in an Off-Site Incinerator, and Confirmatory
Sampling
Preliminary Sampling/Analysis and
Confirmatory Sampling 4,000
Transport, Treatment and Disposal
at a RCRA Incinerator 111,300
Backfill and Revegetation 1,000
Health and Safety Equipment 1.000
Subtotal 117,300
Bid Contingency (15%) 17,595
Scope Contingency (20%) 23.460
Construction Subtotal 158,355
Permitting and Legal Activities (5%) 7,918
Engineering Design (7%) 11,085
Construction Services (8%) 12.668
Total Capital Cost 190,026
ALTERNATIVE 5
SAMPLING AMD CAPPING
Capital Cost : $ 27,230
Annual O&M : $ 500
30 Years O&M : $ 7,700
Present Worth : $ 34,900
Implementation : 2 months
This alternative employs preliminary sampling followed by
capping. Since a cap would be installed, there are long-term
operation and maintenance costs.
The cap, which is multi-layered, would effectively prevent any
further leaching of contamination from the soil into the ground
water by reducing the permeability. The Summers model
calculations for this scenario show that capping virtually
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4r
eliminates infiltration of rainwater, so that there is no longer
any detectable—effeet-on ground water. The cap would consist of,
from the bottom up, a layer such as Gundseal or Claymax (which
acts as a low permeability clay layer), a geomembrane, a sand
layer (for drainage), and a concrete layer (4000 psi). Also, the
cap will be designed to be as thin as possible so as to not
interfere with the doorways along the rear of the fabrication
building.
Since the facility at one time used a solvent that contained
93.5% TCA, the soil is contaminated with a RCRA hazardous waste
(waste codes F001 - F005, 40 C.F.R. § 261.31). The Land Disposal
Restrictions are not ARARs for this alternative. RCRA closure
and post-closure regulations, 40 C.F.R. Part 264, Subpart G are
applicable because the soil containing a RCRA waste is left in
place. Since the waste would be left in place a review will be
conducted within five years, and every five years thereafter, as
required by Section 121(c) of CERCLA, 42 U.S.C. § 9621(C).
The estimated capital cost for Alternative 5 is depicted in Table
16.
Table 16. Estimated Costs for Alternative 5: Sampling and Capping
Preliminary Sampling/Analysis 2,000
Concrete Layer 6,380
Sand Layer 1,700
Geomembrane 3,000
Gundseal/Claymax 3,000
Health and Safety Equipment. 1.000
17,080
Bid Contingency (15%) 2,560
Scope Contingency (20%) 3.420
Construction Subtotal 23,069
Permitting and Legal Activities (5%) 1,150
Engineering Design (7%) 1,160
Construction Services (8%) 1.850
Subtotal Capital Cost 27,230
Operatioruand Maintenance, present
worth 7,686
(Annual review and maintenance for
30 years at a 5% interest rate)
Total Capital Cost 34,920
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41
VIII. Summary of the Comparative Analysis of Alternatives
Each of TRe remedial alternatives for 0173 was compared and
evaluated against nine criteria to determine which remedial
alternative and combination of technologies and process options
would best meet the remedial objectives of this response action.
The evaluation of remedial alternatives against the nine criteria
is required by the NCP, see 40 C.F.R. $ 300.430(e) (9) (iii) . The
comparative evaluation of alternatives allows EPA to select the
option which most appropriately meets the remedial objective for
OU3. The following section defines each of the nine evaluation
criteria and compares each of the remedial alternatives developed
in this ROD against each of the nine evaluation criteria.
Threshold Criteria
A. Overall Protection o^ BtinHta Health and the
whether a remedy provides adequate protection to human health and
the environment and describes how risks posed through each
exposure pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
All of the alternatives, with the exception of the "No Action"
Alternative, would provide adequate protection of human health
and the environment. Since the "No Action" Alternative does not
prevent the further leaching of contamination from the soil to
the ground water, it is not considered further in this analysis
as an option.
B. Compliance with ARARs; whether a remedy will meet all of the
Applicable or Relevant and Appropriate Requirements (ARARs) of
Federal and State environmental laws. Under Section 121(d) of
CERCLA, 42 U.S.C. S 9621 (d), and EPA guidance, remedial actions
at CERCLA sites must attain legally applicable or relevant and
appropriate Federal and State environmental standards,
requirements, criteria, and limitations. Applicable requirements
are those substantive environmental protection requirements,
criteria, or limitations, promulgated under Federal or State law
that specifically address hazardous substances found at a site,
the remedial action to be implemented, the location of a site, or
other special circumstances. Relevant and appropriate
requirements are those substantive environmental protection
requirements, criteria, or limitations promulgated under Federal
or State law which, while not applicable to the hazardous
substances at a site, the remedial action, site location, or
other circumstances, nevertheless address problems or situations
sufficiently similar to those encountered at a site that their
use is well suited to that site.
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4?
Alternatives 2, 4, and 5 would meet their respective applicable
or relevant and—appropriate requirements of Federal environmental
laws.
The selected remedy utilizes Section 121(d)(4)(D) of CERCLA to
waive a State requirement for capping of the area, because it
will achieve an equivalent standard of performance.
Table 17 identifies ARARs for the alternatives developed in this
ROD and Table 18 lists each alternative compliance status with
ARARs.
Primary Balancing Criteria
C. Long-term Effectiveness and Permanence; the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once clean-up goals have been met.
All of the alternatives are effective in the long-term and
permanent, although Alternative 5 is less effective in the long
term than the other alternatives. Alternative 5 provides for
capping. The cap would be designed and constructed to promote
drainage, minimize erosion of the cover, and provide long-term
minimal migration of liquids through the underlying contaminated
soil. Long-term operation and maintenance is required to ensure
the integrity of the cap. Under Alternatives 2 and 4, the
contaminated soil is removed and sent to a RCRA landfill or
incinerated. Alternative 3 provides for the removal of most of
the contamination from the soil.
D. Reduction of Toxicitv, Mobility or Volume of the
Contaminants Through Treatment: the anticipated performance of
the treatment technologies a remedy may employ.
Alternatives 2, 3 and 4 treat the contaminated soil to reduce the
toxicity, mobility, or volume of the organics. Alternative 4
provides for incineration thus destroying the contamination, and
Alternatives 2 and 3 reduce the contamination through soil vapor
extraction. Alternative 5 does not treat the contamination,
would not reduce toxicity or volume but would minimize mobility
and would require long term operation and maintenance.
E. Short-term Effectiveness; the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period, until clean-up goals are achieved.
Alternatives 4 and 5 can be completed in the least amount of time
compared with the other alternatives. Alternatives 2 and 4,
which include excavation, and Alternative 3, which includes some
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Law. Regulation, or Standard
CHEMICAL SPECIFIC
Air Stripper Control Policy (To be
considered)
ACTION SPECIFIC
FEDERAL
RCRA - Samples
RCRA Standards applicable 10 generators of
hazardous waste
RCRA standards applicable to transporters of
hazardous waste
Treatment, Storage, or Disposal of Hazardous
Waste in Miscellaneous Units
RCRA Air Emission Standards for Process
Vents
RCRA Air Emission Standards for Equipment
Leaks
Table 17. CHEMICAL-, ACTION- AND LOCATION-SPECIFIC ARARS
Source of Regulation Description
EPA OSWER Directive 9355.0-28
40 CFR 261.4(d)
RCRA Subtitle C Sections 3001-3019,
40 CFR 262
40 CFR 263 and 49 CFR 171 through
179
40 CFR 264 Subpart X
40 CFR 264 Subpart AA
40 CFR 264 Subpart BB
Suggest that total VOC releases from air
strippers should not exceed 3 Ibs/hr or 15
Ib/day.
Exclusions on samples from being
defined as hazardous waste.
Part 262 establishes standards for
generators of hazardous wastes. This
section requires that generators comply
with the requirements for identification,
accumulation, recordkeeping, and
reporting.
The regulations set forth in 40 CFR 263
(and applicable parts of 40 CFR 262)
establish the responsibilities of
generators and transporters of hazardous
waste in the handling, transporting, and
management of such wastes. These
regulations concern manifesting, labeling,
using proper containers, recordkeeping,
and reporting discharges.
Hazardous Waste Units must meet
certain standards that will ensure
protection of human health and the
environment
This subpart applies to process vents that
manage hazardous waste with organic
concentrations of at least 10 ppmw.
This subparl applies to facilities that
treat, store, or dispose of hazardous
waste.
Alternative Affected
This policy affects Alternatives 2 and 3.
These regulations affect Alternatives 2, 3, 4, and 5.
40 CFR 262 affects Alternatives 2, 3, and 4.
40 CFR 263 affects Alternatives 2, 3, and 4, which involve the
transport of hazardous wastes off-site.
These regulations affect Alternatives 2 and 3.
These regulations affect Alternatives 2 and 3.
These regulations affect Alternatives 2 and 3.
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44
RCRA Land Disposal Restrictions
40CFR268
Standards of Performance for New Stationary Clean Air Act, 40 CFR 60
Source
National Ambient Air Quality Standards
(NAAQS)
STATE
Pennsylvania Air Pollution Control
Regulations
Clean Air Act, 40 CFR 50
25 PA Code Sections 127.1 el. seq.
Pennsylvania Hazardous Waste Regulations 2S PA Code Parts 260 through 265
Pennsylvania Hazardous Waste Regulations 25 PA Code Section 26Z46(c)
LOCATION SPECIFIC ARARS
These regulations identify wastes that are
restricted from land disposal and
establish treatment requirements
necessary before these wastes can be
land disposed.
These regulations establish the general
provisions and performance standards for
stationary sources of air emissions.
These standards define levels of air
quality which are necessary to protect
public health. Standards have been
established for sulfur oxides, paniculate
matter, carbon monoxide, ozone,
nitrogen dioxide, and lead.
Requires that air emissions from new
sources be controlled with best available
technology. In addition, approval is
required for any soil vapor extraction '
plan.
The regulations set the standards
applicable to generators, transporters,
and operators of hazardous waste
facilities in the State of Pennsylvania.
The regulations require the cleanup of
spills so that they no longer present a
hazard to the health and safety of the
public or the environment.
40 CFR 268 affects Alternatives 2 and 4 because these
alternatives involve (he excavation, treatment, or disposal of
hazardous wastes.
These regulations affect Alternatives 2 and 3.
These regulations affect Alternatives 2 and 3 for paniculate
matter.
These regulations affect Alternatives 2 and 3.
Portion* of these regulations affect Alternatives 2, 3, and 4
because these alternatives involve the treatment, storage, or
disposal of hazardous wastes.
These regulations affect Alternatives 2 through 5.
No location-specific ARARs have been
identified for OU3.
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Table 18. ALTERNATIVE COMPLIANCE WITH ARARS
Chemical Specific
Air Stripper Control Policy
Action Specific
FEDERAL
RCRA Samples
RCRA Standards applicable
ALTERNATIVE 1
No Action
NA
NA
NA
ALTERNATIVE 2
SVE and Landfill
TBC
C
C
ALTERNATIVE 3
SVE
TBC
C
C
ALTERNATIVE 4
Incineration
NA
C
C
ALTERNATIVE 5
Capping
NA
.
C
NA 1
to generators of hazardous
waste
RCRA Standards applicable
to transporters of hazardous
waste
Treatment, Storage, or
Disposal of Hazardous Waste
in Miscellaneous Units
NA
NA
NA
NA
NA
Air Emission Standards for
Process Vents
NA
NA
NA
Air Emission Standards for NA
Process Lfakt
RCRA Land Disposal NA
Restrictions
Standards of Performance for NA
New Stationary Sources
National Ambient Air Quality NA
Standards
NA
NA
NA
NA
NA
NA
NA
NA
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46
STATE
Pennsylvania Air Pollution
Control Regulations
Pennsylvania Hazardous
Waste Regulations
(260-265)
Pennsylvania Hazardous
Waste Regulation*
(26Z46(c))
ALTERNATIVE 1
No Action
NA
NA
NA
ALTERNATIVE 2
SVE and Landfill
ALTERNATIVE 3
SVE
C
ALTERNATIVE 4
Incineration
NA
C
ALTERNATIVE 5
Capping
NA
NA
C - Complies with ARAR
NA - Not an ARAR for Ibis alternative
TBC - To be considered
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47
excavation, would pose some short-term risk of exposure to VOCs
during the excavation-process. Under Alternatives 2 and 3, once
the VOCs have been collected in canisters, there is some minor,
short-term risk of exposure to the community during
transportation of the canisters to a treatment facility.
F. Implementabilitv; the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
All alternatives are considered technically implementable. They
utilize proven engineering processes implemented at similar
Superfund sites. The availability of RCRA Subtitle C disposal
capacity could be a limiting factor. There are no associated
administrative difficulties that would impede implementation of
any of the alternatives.
G. Cost; estimated capital, operation and maintenance (O&M),
and net present worth costs.
The estimated cost of each alternative is presented in Table 19 -
Summary of Estimated Costs. The cost of the Alternative 3 is
$ 53,500 - $ 66,420. The cost of Alternative 2 is $ 119,000, the
cost of Alternative 4 is $ 190,000, and the cost of Alternative 5
is $ 34,920.
Modifying Criteria
H. State Acceptance; whether the state concurs with, opposes,
or has no comment regarding the selected remedy.
The Pennsylvania Department of Environmental Resources has
concurred with the selected remedy.
I. ffftninmujty Acceptance; the public's general response to the
alternatives.
The public, generally agreed with EPA's selection of sampling
followed by soil vapor extraction (in-situ or ex-situ) and
confirmatory sampling. A public meeting was held on August 15,
1991. There was no disagreement with the selected remedy voiced
at the meeting. EPA's response to public comments is contained
with Appendix A.
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48
TABLE 19
CryoChem Superfund Site
. Summary of Estimated Costs
Alternative Capitol Cost O&M Cost Present Worth Implementation Time,
($) per yr(S) Cost,($) ^;r i m ir^-l (m..mrh.s)
1. No Action -0- -0- -o- -0-
\
2. Sampling, SVE/ $106,000 $106,000 '
Venting, Landfill, to -0- to 9
Sampling $119,000 $119,000
3. Sampling, SVE/ $ 53,500 $ 53,500
Venting, Sampling to -0- to 9
$ 66,400 $ 66,400
4. Sampling,
Incineration, $190,000 -0- $190,000 2
Sampling
5. Sampling, Cap $ 27,230 $ 500 $ 34,920 2
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49
IX. The Selected Remedy
EPA has selected Alternative 3, Sampling, Soil Vapor Extraction
(In-Situ or Ex-Situ), and Confirmatory Sampling as the remedy for
OU3. The specifics of the remedial system (in-situ or ex-situ)
will be determined during the Remedial Design Study, based upon
best engineering judgement.
This alternative calls for preliminary soil sampling followed by
soil vapor venting or extraction, at an estimated cost of $53,500
(soil venting) to $66,400 (soil vapor extraction). See Tables
14a and 14b for costing breakdowns.
The preliminary sampling shall be performed in the area behind
the fabrication building at the following locations (see Figure
10 - Locations of Preliminary Samples):
1) Soil Vapor Sample Site #13
2) Between Soil Vapor Sample Sites #17 and #22
3) Soil Vapor Sample Site #18
The results of the three samples shall aid in the design of the
soil vapor extraction system.
One sample shall also be taken on the east side of the
fabrication building, from the wet area directly in the front of
the door (near railroad tracks). This location is slightly west
of soil vapor probe location 32.
Another sample shall be taken from the drain outside the
fabrication building, also on the east side of the building, if
there is liquid standing in the drain. A minimum of four
preliminary samples will be taken.
Each sample shall be taken at a depth of approximately 8 to 12
inches, and the samples will be analyzed individually for VOCs.
The location of the three confirmatory samples will be determined
in the field.
In ex-situ soil vapor extraction, the soil is excavated, and
treated within the same area of contamination with a vacuum
extraction system. Oust suppressants such as a water spray will
be used to curtail particulate emissions if necessary. The
extracted vapor is captured in a carbon filter unit, and the
carbon is properly disposed of or regenerated according to
Federal and State regulations. The air stream is sampled at
predetermined time intervals to provide an ongoing evaluation of
the process. Soil remediation is complete when equilibrium
occurs. The soil will be sampled to measure the decrease in the
contaminant levels.
In-situ soil vapor extraction employs the installation of vacuum
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50
extraction probes to remove contaminants from the soil, and
capture of the^extracted vapor in a carbon filter system prior to
release of the air to the atmosphere. The contaminants entrained
in the carbon filters will be properly disposed of or regenerated
according to Federal and State regulations. The concentration of
contaminants is measured in the off-gas from the system prior to
carbon treatment. The system operates until it is effectively
not removing any additional VOCs. The system is then run
intermittently until equilibrium again occurs. The completion
point for the soil remediation will be determined by the
performance in the field, based upon achieving continuous and
pulse-pumping equilibrium. The area will be sampled to measure
the reduction in the concentration of each contaminant.
The shallow water table may decrease the effectiveness of in-situ
soil vapor extraction. In addition, the surface near the trench
may have to be appropriately sealed to decrease the amount of
atmospheric air entering the system and to increase the area of
soil vapor flow. Precautions will be taken to ensure the
integrity of the fabrication building.
Any water captured during in-situ soil vapor extraction will be
discharged to the ground water pump and treat system, currently
being designed.
Some changes may be made to the remedy as a result of the
remedial design and construction process. Such changes, in
general, reflect modifications resulting from the engineering
design process.
EPA does not intend to continue remediation for OU3 beyond the
soil vapor extraction since it is known that levels in the soil
will be below levels that are protective of human health.
X. Statutory Determinations
The selected remedy satisfies the remedy selection requirements
of Section 121 of CERCLA (42 U.S.C. Section 9621) and the NCP (40
C.F.R. Section 300.430(e)). The remedy provides protection of
human health and the environment, achieves compliance with ARARs,
utilizes permanent solutions to the maximum extent practicable,
contains treatment as a principal element, and is cost effective.
A. Protection of Human Health and the Environment: The
selected remedy is protective of human health and the
environment. By reducing the amount of contamination in the
soil, the potential for contamination leaching from the soil into
the ground water is reduced. EPA expects that the combination of
the soil remediation and the remedial action for OU2 will form a
system that strives to meet background conditions in the
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51
groundwater.
EPA expects to meet air quality standards in the off-gas from the
system.
Implementation of the selected remedy will not pose unacceptable
short-term risks or cross-media impacts.
B. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs): The selected remedy will comply with all
Federal ARARs. An ARAR waiver will be used for 25 Pa. Code Ch.
75 (hereinafter cited as "25 Pa. Code") §§ 265.1, 265.300, and
265.310 under Section 121(d)(4)(D) of CERCLA, 42 U.S.C. §
9621(d)(4)(D), since an equivalent standard of performance will
be attained.
PADER seeks a degree of remediation such that the soil remedy,
combined with the selected remedy for OU2, will remediate the
ground water to background levels of contamination. The
Pennsylvania ARAR for ground water for hazardous substances is
that ground water must be remediated to "background" quality as
specified by 25 Pa. Code §§ 264.90-264.100 and in particular 25
Pa. Code §§ 264.97(i),(j) and 264.100(a) (9). The Commonwealth of
Pennsylvania also maintains that the requirement to remediate to
background is also found in other legal authorities.
With respect to the spill area, PADER identified potential ARARs
in a letter dated August 7, 1991, stating that "Pa. Code §§
204.1(sic), 264.300 and 264.310 require capping of the disposal
area. Even if the disposal activities at the site ceased before
September 26, 1982, the site would fall within the guidelines of
25 Pa. Code §§ 265.1, 265.300, and 265.310." Under either set of
regulations, PADER would require a final cover (closure and post-
closure care of a landfill).
25 Pa. Code Part 264 sets forth the minimum standards for new
hazardous waste management facilities and the closure and post-
closure care of a hazardous waste surface impoundment, waste
pile, land treatment or landfill facility that accepted hazardous
waste on or after July 26, 1982 which does not have a hazardous
waste permit.
25 Pa. Code Part 265 establishes minimum standards for management
of hazardous waste during the period of interim status, and
applies to owners or operators of facilities in existence on
November 19, 1980, who have failed to provide timely
notification.
Since CryoGhem, Inc. is not a new facility and it appears that
the spill occurred before July 26, 1982, EPA has determined that
25 Pa. Code §§ 265.1, 265.300, and 265.310 are the relevant
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5?
regulations to examine. 25. Pa. Code § 265.300 specifically
applies to owners and.-operators of facilities that dispose of
hazardous waste in landfills (including waste piles used by
disposal facilities). 25 Pa. Code § 265.310 addresses closure
and post-closure care at such facilities.
EPA believes that the area behind the fabrication building is a
spill area. The Pennsylvania Regulations define a spill as a
"discharge" which is an "intentional or accidental spilling,
leaking, pumping, pouring, dumping, emitting or other release of
hazardous wastes, hazardous waste constituents or hazardous
materials which, when released into or onto land or water,
becomes hazardous waste." A landfill is defined as a "disposal
facility or part of a facility where hazardous waste is placed in
or on land...." A disposal facility is defined as a "facility or
part of a facility at which hazardous waste is placed into or on
land or water and at which waste will remain after closure."
See, 25 Pa. Code Part 260.
PADER asserts that once the spill occurred and was left in place,
the area behind the fabrication building became a hazardous waste
disposal facility, per their definitions. EPA recognizes this
interpretation and finds that 25 Pa. Code §§ 265.1, 265.300, and
265.310 are relevant and are appropriate.
EPA believes that the soil vapor extraction remedy for OU3
combined with the ground water pump and treat system for OU2
forms a system designed to meet the background requirements for
the ground water. These systems, acting together, will attain a
standard of performance that is equivalent to the landfill
closure and post-closure care required by 25 Pa. Code §§ 265.1,
265.300, and 265.310. Therefore, EPA is waiving the requirements
of 25 Pa. Code §§ 265.1, 265.300, and 265.310 under Section
121(d)(4)(D) of CERCLA.
EPA believes that 25 Pa. Code § 262.46(c) is an ARAR related to
spills, which specifically addresses cleanups of spills due to
plant operation. Under that regulation a generator shall "...
take actions that may be required or approved by the Department
so that the discharge or spill no longer presents a hazard to the
health and safety of the public or the environment".
In additioji, the following action-specific ARARs will be attained
by the selected remedy (chemical-specific and location-specific
ARARs have not been identified for OU3):
• Resource Conservation and Recovery Act (RCRA)
40 C.F.R. § 261.4(d), which describes the conditions
under which a sample would not be considered a
hazardous waste.
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53
40 C.F.R. Part 262, which establishes standards for
generators of" hazardous waste. The carbon units will
be considered a hazardous waste.
40 C.F.R. Part 264, Subpart AA, which sets the
requirements for Air Emission Standards for Process
Vents.
40 C.F.R. Part 264, Subpart BB, which sets the
requirements for Air Emission Standards for Process
Leaks.
• Clean Air Act
40 C.F.R. Part 60, which establishes the general
provisions and performance standards for stationary
sources of air emissions.
40 C.F.R. Part 50, which includes standards that define
levels of air quality which are necessary to protect
public health. The standards for particulate matter
shall be met.
• State Regulations
Pennsylvania Air Pollution Control Regulations, 25 Pa.
Code §§ 127.1 et seq.. which requires that air
emissions from new sources be controlled with the best
available technology.
Pennsylvania Hazardous Waste Regulations, 25 Pa. Code
Parts 260 through 265, which includes regulations that
set the standards applicable to generators,
transporters, and operators of hazardous waste
facilities. The carbon units will be considered a
hazardous waste.
Pennsylvania Hazardous Waste Regulations, 25 Pa. Code §
262.46(c), which states that hazardous waste discharges
or spills shall be cleaned so that the discharge or
spill no longer presents a hazard to the health and
safety of the public or the environment.
EPA also considers policies and procedures that are not legally
binding, but to-be-considered (TBC). This includes the Air
Stripper Control Policy (EPA OSWER Directive 9355.0-28). This
policy suggests that the total VOC releases from air strippers
should not exceed 3 Ibs/hr, 15 Ib/day, or 10 tons/yr of total
VOCs.
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5'
In the development of this ROD, the goals of OU2 are taken into
consideration »ince -soi-1 contamination affects ground water. In
the ROD for OU2, on page 32, EPA stated:
"In order to restore the aquifer to its beneficial use, the
remediation system implemented in each of the alternatives would
operate until Site-specific remediation goals are achieved. Thus
the aquifer would be remediated until the contaminate levels
reach the MCLs, Non-zero MCLGs, or background, whichever are
lower.
If implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence that it
will be technically impracticable to achieve and maintain the
remediation goals throughout the area of attainment, the USEPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals."
To the extent practicable, OU3 will be remediated to a degree
which is consistent with the goals of the remedy for OU2. The
remediation for OU3, coupled with the remedial action for OU2,
forms a system intended to meet the requirements of the State
environmental laws.
Although EPA and PADER believe that the removal of the
contamination from the soil may reduce that amount of time
required for the pump and treat system, there is no existing data
to demonstrate such.
The soil contains a RCRA hazardous waste, but the levels of
contamination in the soil are below levels currently considered
by EPA to be within the acceptable risk range. After
remediation, the status of the soil will continue to be such that
the concentrations of the listed wastes are below health based
levels, and the soil would no longer "contain" the hazardous
wastes.
Under EPA's "contained-in" policy, "contaminated media (i.e.,
debris, soil, grcundwater, sediments) that contain RCRA wastes
must be managed as if they were hazardous waste until the media
no longer contain the hazardous waste (i.e., until
decontaminated) or until they are delisted. To date, [EPA] has
not issued any definitive guidance as to when, or at what levels,
environmental media contaminated with hazardous waste no longer
contain the hazardous waste. Until such guidance is issued,
[EPA] or authorized States may determine these levels on a case-
specific basis. [EPA] also suggests that when making a
determination as to when contaminated media no longer contains a
hazardous waste that a risk assessment approach be used that
addresses the public health and environmental impacts of the
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55
hazardous constituents remaining." 56 Fed. Reg. 24456 (May 30,
1991) . —- - "-
EPA has previously determined that no direct contact risk exists
due to the contaminated soil behind the fabrication building.
Utilizing the Summers model, the soil is expected to currently
affect the ground water below MCLs. After careful consideration
of the multiple operable unit approach to remediation at the
Site, EPA has determined that upon implementation of the remedy,
OU3 at the Site will no longer contain RCRA hazardous waste.
The completion point for the soil remediation will be determined
by the performance in the field, based upon achieving equilibrium
in the system. Confirmatory sampling will be performed to
measure the amount that the contaminant levels have been reduced.
EPA does not intend to continue remediation for OU3 beyond the
soil vapor extraction (in-situ or ex-situ) since it is known that
levels in the soil will be below levels that are protective of
human health.
None of the alternatives would cause a violation of National
Ambient Air Quality Standards (NAAQS) due to fugitive dust
generated during construction activities (Clean Air Act, 40
C.F.R. Part 50).
Transportation of material to RCRA permitted facilities will be
done in compliance with Federal and State regulations applicable
to generators and transporters of hazardous wastes.
As in OU2, if implementation of the selected remedy demonstrates,
in corroboration with hydrogeological and chemical evidence, that
it will be technically impracticable to achieve and maintain the
remediation goals throughout the area of attainment, the EPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the public of alternative ground water goals.
The Land Disposal Restrictions are an ARAR when "placement"
occurs as part of an alternative. Alternatives 2 and 4 involve
placement since contaminated soil would be disposed or treated
off-site. The Land Disposal Restrictions are not an ARAR for
Alternatives 3 and 5 since the soil is treated within the same
area of contamination for soil vapor extraction or capping.
A complete listing of ARARs and TBCs for all alternatives can be
found in Table 17.
C. Cost Effectiveness: The selected remedy, which is expected
to cost from $53,500 to $66,400, depending on whether in-situ or
ex-situ soil vapor extraction is used, affords overall
effectiveness and protects human health and the environment
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56
proportional to its costs. The only remedy which is less
expensive is Alternative 5 - Capping, which costs $34,900, but it
does not satisfy other selection criteria below.
D. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable: The removal of
hazardous wastes contained in soil, to the extent practicable
provides a permanent solution to the potential release of
hazardous constituents to the groundwater system. This will
ensure that these hazards do not provide a health risk to nearby
residents. The treatment technology to be utilized, although
considered innovative, is efficient and cost effective. The
selected remedy meets the statutory requirement to utilize
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
E. Preference for Treatment as a Principal Element: The
selected remedy utilizes proven and readily available treatment
technologies and meets the statutory preference for treatment as
a principal element. Soil vapor extraction will be utilized to
address the contaminated soil, which is expected to affect the
ground water at the Site. The contaminated ground water is the
primary risk posed by the Site, since it is used by nearby
residents.
XI. Documentation of Significant Changes
The Proposed Plan was released for public comment on August 8,
1991. The Plan used the terminology "soil vapor extracting" and
"soil vapor venting" to describe several of the alternatives.
Both methods utilize the same basic technology. Soil vapor
extraction referred to an in-situ method, and soil vapor venting
referred to an ex-situ method. In this ROD, however, the term
"Soil Vapor Extraction" is used broadly and covers both ex-situ
and in-situ. Where differences between the two are discussed,
in-situ or ex-situ is specified.
In a letter received after the issuance of the Proposed Plan,
PADER identified additional regulations that they considered
ARARs, specifically 25 Pa. Code §§ 264.1, 264.300, 264.310 or 25
Pa. Code §§ 265.1, 265.300, 265.310, which specify closure and
postclosure care of a landfill. After consideration, EPA
determined that 25 Pa. Code §§ 265.1, 265.300, and 265.310 were
relevant and appropriate. EPA has waived these requirements,
citing Section 121(d)(4)(D) of CERCLA, which allows waivers when
the selected remedial action will attain an equivalent standard
of performance as compliance with the ARAR. The soil vapor
extraction system, in conjunction with the ground water pump and
treat system, will attain an equivalent standard of performance.
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57
This ROD specifies that any water captured during soil vapor
extraction will be treated within the pump and treat system for
Operable Unit~2". Therefore, any contamination within the
captured water will be properly treated.
-------
Appendix A. Responsiveness Summary
CryoChem Superfund Site
—- - ._- operable Unit 3
A. Overview
The EPA preferred remedial alternative for the contaminated soil
(OU3) was outlined in the Proposed Plan and released to the
public on August 8, 1991. . During a 30-day public comment period
(August 8, 1991 through September 9, 1991) and during a public
meeting conducted August 15, 1991, the public was provided the
opportunity to submit comments on EPA's preferred alternative.
In general, the public provided comments which supported EPA's
preference to treat the contaminated soil by soil vapor
extraction or venting. Two written comments relating to the Site
were received by EPA during the comment period, and all other
comments were delivered at the public meeting. Based upon a
comparative analysis of several remedial alternatives and upon
public comments received during the 30-day comment period, EPA
has selected Alternative 3; Preliminary sampling, soil vapor
extraction (in-situ or ex-situ), followed by confirmatory
sampling. The ROD details the remedial alternative selected by
EPA.
B. Summary of Comments
The public comment period was held from August 8, 1991 through
September 9, 1991. A public meeting was held August 15, 1991. A
stenographic report of the public meeting was prepared by EPA.
EPA received one letter from the public specifically concerning
OU3 following the public meeting, and one letter from PADER. In
response to the letter from the citizen, EPA included two
additional preliminary samples to be taken to the east of the
fabrication building. Comments received at the public meeting
are contained within a Stenographic Report of Public Hearing held
at the Earl Township Municipal Building, Route 73, Boyertown,
Pennsylvania, August 15, 1991.
Comments concerning OU3 are summarized below. Following each
comment summary is EPA's response.
Process
EPA received comments concerning the length of time which passed
before any response action was taken at the Site.
EPA Response - Prior to implementing a remedy at a Superfund
site, EPA is required, pursuant to the NCP, to conduct studies
intended to determine the nature and extent of contamination at a
site, the risks posed by that contamination, and a range of
alternatives for responding to the risks posed by the site. Upon
-------
completion of these studies, EPA can then select the alternative
which best add««sses the risks posed by the site for the most
reasonable costs. In order for EPA to expend public funds
addressing the remediation of the site contamination, the site
must first be listed on the National Priorities List (NPL). This
Site was listed on the NPL in October 1989. Prior to October
1989, the work conducted at the Site to determine appropriate
response actions for contaminated ground water was conducted by
the potentially responsible parties.
Technical concerns Regarding Alternatives
1. A concern was raised about the potential for noise from the
soil vapor extraction or venting process.
EPA Response - Although there will be equipment behind the
fabrication building to perform the remediation, the system can
be designed to operate quietly.
2. One resident expressed concern that CryoChem, Inc. had
disposed of solvent on the east side of the fabrication building,
both alongside the building and down an outside drain in the
area.
EPA Response - During the soil gas survey that was conducted
during the Remedial Investigation, six samples were taken to the
east of the fabrication building. However, these samples were
not in the specific area mentioned by the resident, so EPA
intends to conduct further sampling during the preliminary
sampling at the Site to address these concerns.
3. PADER sent a letter, dated August 7, 1991, to EPA (and
received by EPA after the issuance of the Proposed Plan) which
states, in part, the following: "The proposed plan should
include a discussion about capping, which is a state ARAR. Based
upon our information and belief concerning CryoChem's activities
at the site, disposal of hazardous waste occurred after September
26, 1982. Therefore, 25 Pa. Code §§ 204.1(sic), 264.300 and
264.310 require capping of the disposal area. Even if the
disposal activities at the site ceased before September 26, 1982,
the site would fall within the guidelines of 25 Pa. Code §§
265.1, 265^.300, and 265.310."
EPA Response - EPA has addressed the regulations at 25 Pa. Code
§§ 264.1, 264.300, 264.310 and §§ 265.1, 265.300, 265.310 in
detail in this ROD under Section X.B., Compliance with Applicable
or Relevant and Appropriate Requirements (ARARs).
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Briefly, EPA determined that the regulations under 25 Pa. Code
Part 265 were tke relevant and appropriate set of regulations to
consider (and not the regulations under 25 Pa. Code Part 264).
EPA concluded that the 25 Pa. Code Part 265 regulations were
relevant and appropriate, but waived the regulations, since the
selected remedy would meet an equivalent standard of performance.
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Appendix B. Administrative Record Index
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PENNSYLVANIA
7.5 MINUTE SERIES (TOPOGRAPHIC)
SCALE 1 24000
"LE
1000
1000 JOOO 3000 «CO 500C 6000 '300 nf
t
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CRYOCHEM OU3
ADMINISTRATIVE RECORD FILE *
— - -- INDEX OF DOCUMENTS
I. SITE IDENTIFICATION
*** 1. Letter to Mr. Anthony T. Calzolaio, CryoChem, Inc.,
from Mr. Robert E. Day-Lewis, PADER, re: Findings
from August 10, 1982 meeting and plant inspection,
10/12/82.
*** 2. Report: Site Inspection of CryoChem, Incorporated,
prepared by NUS Corporation, 5/13/85. '.
*** 3. Letter to Mr. Russell H. Wyer, U.S. EPA, from Mr.
Anthony Calzolaio, CryoChem, Inc., re: Spillage of
Trichloroethane, 7/25/86. A hand-drawn map of the
CryoChem property is attached.
* Administrative Record File available 6/17/91, updated
7/30/91, updated 8/8/91.
** This document can be found in the CryoChem OU1
Administrative Record File.
*** This document can be found in the CryoChem OU2
Administrative Record File.
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II. REMEDIAL ENFORCEMENT PLANNING
*** 1. Administrative Order by Consent in the Matter of the
CrydChem Sire, 2/14/88.
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III. REMEDIAL RESPONSE PLANNING
***
***
***
***
***
***
Report: Preliminary Health Assessment for CryoChem,
Incry prepared by the Agency for Toxic Substances
and Disease Registry (ATSDR), 12/2/88.
Report: Final Remedial Investigation Report for the
CryoChem Site, Volume I, prepared by JACA Corp.,
6/6/90.
Report: Final Remedial Investigation Report for the
CryoChem Site, Volume II, prepared by JACA Corp.,
6/6/90.
Report: Final Remedial Investigation Report for the
CryoChem Site, Volume III/ prepared by JACA Corp.,
6/6/90.
Report: Final Feasibility Study for the CryoChem
Site, prepared by JACA Corp., 6/22/90.
Letter to Mr. Ronald Putt, CryoChem, Inc., from Mr.
Michael Towle, U.S. EPA, re: Remedial Investigation
Report, Feasibility Study Report, 5/22/90. The
following are attached:
a) Final Remedial Investigation Report
Comments;
b) comments on the Draft Feasibility Study;
c) calculations indicating that "soil" may
require remediation;
d) additional environmental/chemical
characterization;
e) a "pre-design" study outline;
f) CryoChem Site Risk Assessment conducted by
EPA.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Bruce Beach, Dynamac Corporation, re: Draft letter
report, 8/15/90. The report is attached.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
ichael Keefe, Planning Research Corporation, re:
Cost estimate for soil vapor extraction, 8/31/90.
P. 300001-300001.
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9. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Bruce Beach, Dynamac Corporation, re: final letter
report on Feasibility Study alternatives, 9/13/90.
P.-§00002-300018. The letter report is attached.
10. Memorandum to Ms. Lisa Nichols, U.S. EPA, from Ms.
Nancy L. Cichowicz, U.S. EPA, re: Technical review
of calculations indicating that the soil may require
remediation, 11/26/90. P. 300019-300027. The
following are attached:
a) Summers Method Determination of Soil
Action Level for 1,1,1-Trichloroethane at
CryoChem;
b) Summers Method Determination of Soil
Action Level for 1,1-Dichloroethane;
c) two charts of Summers Method Determination
of Soil Action Level for Tetrachlorethane;
d) Summers Method Determination of Soil
Action Level for Trichloroethane;
e) Summers Method Determination of Soil
Action Level for Ethyl Benzene;
f) Summers Method Determination of Soil
Action Level for Xylene.
11. Memorandum to Ms. Lisa Nichols, U.S. EPA, from Dr.
Roy L. Smith, U.S. EPA, re: Carcinogenic
classification of 1,1-DCA, 1/2/91. P. 300028-
300028.
12. Memorandum to Ms. Lisa Nichols, U.S. EPA, from Dr.
Roy L. Smith, U.S. EPA, re: Risks associated with
soil contamination at CryoChem, 2/14/91. P. 300029-
300030.
13. Report: Focused Feasibility Study for Operable Unit
3, CryoChem Site, prepared by Dynamac Corporation,
5/15/91. P. 300031-300076.
14. Memorandum of telephone conversation to file from
Ms. Lisa Nichols, U.S. EPA, re: PADER comments on
the feasibility study, 6/5/91. P. 300077-300077.
15. Letter to Ms. Lisa Nichols, U.S. EPA, from Mr.
Ronald F. KliniJcowski, PADER, re: PADER comments on
the proposed plan and focused feasibility study,
6/7/91. P. 300078-300080.
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16. Memorandum to Ms. Lisa Nichols, U.S. EPA, from Dr.
Roy L Smith, U.S. EPA, re: Weight of evidence
classification for 1,1-DCA, 6/14/91. P. 300081-
300081.
17. Cost Comparisons for Low Temperature Systems (LTVS)
at Four Superfund Sites, U.S. Army Corps of
Engineers, Kansas City District, 1/91. P. 300082-
300110.
18. Letter to Ms. Lisa Nichols, U.S. EPA, from Mr.
Ronald F. Klinikowski, PADER, re: State ARARs,
1/8/91. P. 300111-300111.
19. Memorandum to Ms. Lisa Nichols, U.S. EPA, from Ms.
Joan Durkin and Mr. David Ignatuk, L.A. Salomon,
Inc., re: Facts about Claymax, 7/11/91. P. 300112-
300117.
20. Letter to Ms. Lisa Nichols, U.S. EPA, from Mr.
Michael A. Johnson, PRC Environmental Management,
Inc., re: HELP model runs for four capping
scenarios, 7/12/91. P. 300118-300136.
21. Summers Method Determination of Soil Action Level
for Xylene, 3 scenarios, prepared by Ms. Lisa
Nichols, (undated). P. 300137-300139.
22. Summers Method Determination of Soil Action Level
for Benzene, 3 scenarios, prepared by Ms. Lisa
Nichols, (undated). P. 300140-300142.
23. Summers Method Determination of Soil Action Level
for 1,1-Dichloroethane, 3 scenarios, prepared by Ms;
Lisa Nichols, (undated). P. 300143-300145.
24. Summers Method Determination of Soil Action Level
for PCE, 3 scenarios, prepared by Ms. Lisa Nichols,
(undated). P. 300146-300148.
25. Summers Method Determination of Soil Action Level
for 1,1,1-Trichloroethane, 3 scenarios, prepared by
Ids. Lisa Nichols, (undated). P. 300150-300152.
26. Summers Method Determination of Soil Action Level
for Tricloroethene, 3 scenarios, prepared by Ms.
Lisa Nichols, (undated). P. 300153-300155.
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27. Letter to Mr. Ronald F. Klinikowski, PADER, from Ms
Lisa Nichols, U.S. EPA, re: Proposed plan, 7/15/91.
P. 300156-300157.
28. Costing Calculations and handwritten notes, prepared
by Ms. Lisa Nichols, (undated). P. 300158-300160.
29. Report of Conversation of Ms. Lisa Nichols, U.S.
EPA, with Mr. Carl Elliot, Stout Environmental, re:
Cost for soil removal, 7/16/91. P. 300161-300161.
Cost estimates are attached.
30. Costing Calculations and handwritten notes, prepared
by Ms. Lisa Nichols, (undated). P. 300162-300166.
31. Report of Conversation of Ms. Lisa Nichols, U.S.
EPA, with Dr. Dennis Chilcote, Biotrol, re: Soil
washing estimates, 7/17/91. P. 300167-300167.
32. Letter to Ms. Lisa Nichols, U.S. EPA, from Ms.
Pamela Sheehan, Biotrol, re: Removal of soil,
7/17/91. P. 300168-300171.
33. Memorandum to Mr. Thomas Voltaggio, U.S. EPA, from
Mr. John J. Humphries, U.S. EPA, re: Proper design
of an "EPA" cap, 5/23/90. P. 300172-300173.
34. U.S. EPA Engineering Bulletin, "In Situ Soil Vapor
Extraction Treatment," 5/91. P. 300174-300184.
35. Letter to Ms. Lisa Nichols, U.S. EPA, from Mr. Mark
Cadwallader, Gundle Lining Systems, Inc., re:
Treatment processes for soil and handwritten cost
estimates, 6/18/91. P. 300185-300187.
36. Memorandum to Mr. Abe Ferdas, U.S. EPA, from Mr.
Paul Nadeau, U.S. EPA, re: Comments on selection of
remedy for the site, 7/16/91. P. 300188-300189.
37. Letter to MSi Lisa Nichols, U.S. EPA, from Ms.
Pamela Sheehan, BioTrol, re: Removal of chlorinated
solvents from soil, 7/17/91. P. 300190-300206.
— Fact sheets are attached.
38. Letter to Ms. Lisa Nichols, U.S. EPA, from Mr.
Ronald F. Klinikowski, PADER, re: Comments on the
proposed plan, 7/25/91. P. 300207-300207.
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39. Letter to Mr. Ronald F. Klinikowski, PADER, from Ms.
Lisa Nichols, U.S. EPA, re: Comments on the
proposed plan, 8/2/91. P. 300208-300209.
40. Costing calculations, prepared by Ms. Lisa Nichols,
(undated). P. 300210-300211.
41. Letter to Mr. Michael Keefe, PRC Environmental
Management, from M. Johnson, Stout Environmental,
Inc., re: Preliminary pricing information for
solvent contaminated soil, 8/15/90. P. 300212-
300213. A facsimile cover sheet is attached.
42. Memorandum to Mr. Ron Klinikowski, PADER, from Ms.
Ruth Bishop, PADER, re: Review of Summer's model
results, 6/27/91. P. 300214-300215. A facsimile
cover sheet is attached.
43. Costing Calculations and handwritten notes, prepared
by Ms. Lisa Nichols, (undated). P. 300216-300218. .
40. U.S. EPA Proposed Plan, Cryochem Superfund Site,
Operable Unit 3, 8/8/91. P. 300219-300238.
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
IMAGERY
* * * 1. Report: 'Final Draft Community Relations Plan,
CryoChem Superfund Site, prepared by the U.S. EPA,
7/16/90.
8
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Appendix C. RI/FS Sampling Data
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Table 7-1
CryoChem Site RI
CHEMICALS DETECTED DURING THE REMEDIAL INVESTIGATION
Cheat ca!
(CAS No.)
Acetone
(67-64-1)
Chlorobenzene
(108-90-7)
Chloroform
(66-67-3)
1.1-Dtchloroethane
(75-34-3)
1.1-Dlchloroethene
(75-35-4)
Ethylbenzene
(100-41-4)
Mcthylene Ctilortde
(75-09-2)
Methyl Ethyl Ketone
(78-93-3)
4-Nethy1-2-PenUnone
(108-10-1)
Styrene
(100-42-5)
1 . 1 ,2,2-Tetrachloroethane
(79-34-5)
Tetrachloroethene
(127-18-4)
Toluene
(108-88-3)
1.1,1-TMchloroethane
(71-55-6)
Trlchloroethene
(79-01-6)
t IN VARIOUS ENVIRONMENTAL HUH A
'
Concentrations In parts per billion (ppb)
Groundwater Surface water
ff Analyzed/ f Analyzed/
Nln. NBK. Rep. 1 Detected Ntn. Max. Rep. t Detected Mtn.
0
0
0 84 9.9 258/215 0 5 3.5 13/4 0
0 1734 87 258/199 0 7 4.2 13/5 0
0
0
0
0
0 12 2.8 258/174 0
0
0 1582 189 258/229 0 150 45.4 13/6 0
0 77 6.6 258/184 0
Max.
3500
23
4200
15
920
370
300
15
460
7
210
61
son
Rep.
1082
23
2101
15
920
237.5
35.5
7.6
256.6
2.3
581
17.1
f Analyzed/
* Detected
37/35
37/22
37/2
37/1
37/1
37/36
37/14
37/13
37/9
37/21
37/3
37/3
f
\ sediment
f Analyzed/
Ntn. Max. Rep. 1 Detected
i
i
0 55 6/1
0 5 3.5 6/2
0 55 6/1
0 44 6/1
0 66 6/1
0 6 3.3 6/3
0 13 13 6/1
0 33 6/1
-------
Table 7-1
(Continued)
Chemical '
(CAS No.) srounoxaier
I Analyzed/
Nln. Max. Rep. f Detected
Xylenes
(1330-20-7)
b1s(2-Ethylhexyl)Phtbalate 0 10 6.5 13/6
(117-81-7)
Dl-n-butylphthalate
(84-74-2)
Chlordane
(57-74-9)
Netal
(CAS No.) eroundwater
AlMlnw 0 0.47 0.47 3/1 0
(7429-90-5)
Ant tinny
(7440-36-0)
Arsenic 0 0.03 0.03 26/1
(7440-38-2)
BarlM 0 0.36 0.23 43/3 0.201
(7440-39-3)
Beryl I1i»
(7490-41-7)
Cadnlui 0.017
(7440-43-9)
CalcluB 0 85.8 41 10/8
(7440-70-2)
ChrnluM VI 0 0.018 0.012 43/5
(7440-47-3)
Concentrations In parts per billion (ppb)
Surface water soil sediment
f Analyzed/ r Analyzed/ f f Analyzed/
Mln. Max. Rep. f Detected Nln. Max. Rep. f Detected Mtn. Max1. Rep. 1 Detected
0 4 3.5 13/2 064 6/2
56 150 114 4/4 0.46 2100 1280 2/2
022 2/1
13 14 13.5 37/1 0 2/1
Concentrations In ng/1
surface water soil wj/kg sediiwnt
0.229 0.229 3/1 19.600 47.600 33.600 2/2 1,550 7.020 4.285 2/2
3/0 0.072 0.14 0.11 2/2
3/0 0 42.3 8.86 31/30 0.58 5.5 2.31 7/7
0.397 0.256 13/6 0 712 118.31 31/29 7.9 89.8 55.6 7/7
0.0 3/0 0 9.3 9.3 2/1 0.36 0.63 0.50 2/2
0.235 0.125 13/8 0 22.8 3.84 31/27 0.36 2.4 1.03 7/7
3/0 2.560 3.320 2,940 2/2 401 41.200 20,801 2/2
13/0 0 164 26.51 31/29 2.2 58.2 17.3 7/7
<-*>
i
i
-------
Table 7-1
(Continued)
Metal
(CAS No.)
Cobalt
(7440-48-4)
Copper
(7440-50-8)
Iron
(15438-31-0)
Lead (Inorg.)
(7439-92-1)
Nagnestui
(7439-95-4)
Manganese
(7439-96-5)
Mercury (Inorg.)
(7439-97-6)
Nickel
(7440-02-0)
PotasslM
(7440-09-7)
SelenlM
(7782-49-2)
Silver
(7440-22-40)
SodlM
(7440-23-5)
Vanadium
(7440-62-2)
Concentrations In mg/l
GropmMCteir
Nln.
0
0
0
0
0.1
0.11
0.76
0
3.7
0.051
Max.
0.077
4.4
0.087
29
0.456
0.21
2.1
0.021
5.9
0.24
Rep.
0.052
0.%
0.028
12.1)
0.2?
O.i:i
1.6
0.016
4.7
0.12
f Anal./
f Oet.
10/2
11/11
26/9
8/8
3/3
8/8
3/3
17/5
3/3
6/6
surface water
f Anal./
Mln. Max. Rep. 1 Det.
3/0
3/0
0.15 0.94 0.55 3/2
13/0
0 18.1 18.1 3/1
0 0.016 0.016 3/1
13/0
3/0
3.0
0.007 0.008 0.007 13/3
13/0
0 56.2 56.2 3/1
3/0
Mln.
20.2
29.8
93.800
4.3
3,630
1,610
0.011
47.6
1.070
0
0
893
107
soil
Max.
21.2
49.8
121,000
573
4.930
12.800
0.37
68.4
1.880
39.7
1.0
1.280
130
ng/kg
Rep.
20.7
39.8
107.400
57.76
4,280
14.410
0.091
58.0
1,475
2.43
0.46
1.086.5
118.5
f AnalJ
t Det.
2/2
2/2
2/2
31/31
2/2
2/2
31/31
212
2/2
31/29
31/18
2/2
2/2
Mln.
3.6
1.8
5.360
7.6
35.4
0.014
2.2
49.1
0.085
0.13
77.5
3.6
sediment
Max.
6.3!
31.2
27,000
1
76.4
287
0.069
16.1
723
1.1
4.0
248
15.1
Rep.
5.0
16.5
16.180
37.4
3,210
161
0.036
9.2
386
0.66
1.20
163
9.4
f Anal./
f Det.
2/2
2/2
2/2
7/7
2/2
2/2
7/7
2/2
2/2
7/7
7/7
2/2
2/2
-------
Table 7-1
(Continued)
Metal * Concentrations In «g/l
(CAS No.) '. srowMMateTsurface Mater son ing/Kg ~ seaiaent
f AMI./ f Anal./ r Anal./ r Anal./
Nln. NM. Rep. I Oct. Ntfl. Max. Rep. f Oet. Nln. Max. Rep. I Oct. Nln. Max.i Rep. I Oct.
Zinc 0 0.2S 0.069 11/9 0.04? 0.115 0.062 3/3 152 257 204.5 2/2 17.9 173 95.4 2/2
(7440-66-6)
ThalllM 3/0 0 0.41 0.41 2/1 0.072 0.13 0.1 2/2
(7440-28-0) i
-------
Appendix D. Letter of Concurrence
-------
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Southcentral Regional Office
One Ararat Boulevard
Harrisburg, Pennsylvania 17110
(717) 657-4585
September 30, 1991
Mr. Edwin B. Erickson
Regional Administrator
USEPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence.
Final Draft Record of Decision
Cryochen site
Earl Twp., Berks County
Dear Mr. Erickson:
The final draft Record of Decision (ROD) for Operable Unit 3 at the
Cryochen Site, was received on September 17, 1991 and has been reviewed
by the Department. It is my understanding that this Record of Decision
will be submitted to you for your approval.
The proposed remedy for this last operable unit consists of the
following major components:
* Sampling the contaminated area (and sampling potentially two
other areas) to better define the contamination;
* Utilization of soil vapor venting or extraction to remove the
contamination at the site;
* Confirmation sampling.
On behalf of the Department, I hereby concur with the EPA's
proposed remedy, subject to the following conditions:
* That the soil vapor extraction combined with groundwater pump
and treat system for OU2 forms a system designed to meet the
background requirements for the groundwater in accordance with
EPA's waiver of the requirements of Pa. code §§ 265.1, 265.300,
and 265.310 under CERCLA § 121(d)(4)(D).
* EPA will assure that the Department is provided an opportunity
to fully participate in any negotiations with responsible
parties.
-------
Mr. Erickson
Septeber 30, 1991
Page 2
* The Department will be given the opportunity to review and
comment on documents and concur with decisions related to the
design and implementation of the remedial action, to assure
compliance with Pennsylvania ARARs.
* The Department's position is that its design standards are ARARs
pursuant to SARA section 121, and we will reserve our right to
enforce those design standards.
* The Department will reserve our right and responsibility to take
independent enforcement actions.
* This concurrence with the selected remedial action is not
intended to provide any assurances pursuant to SARA Section
104(c)(3).
Thank you for the opportunity to comment on this EPA Record of
Decision. If you have any questions regarding this matter, please do
not hesitate to contact me.
cher Ph.D.. P.E.
southcentral Region
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